Privacy Policy

1. Purpose 

The purpose of this Privacy Policy is to inform people (hereinafter, users or interested parties) who visit our website (hereinafter, web page, website or web), how we collect, process and protect the personal data you choose to provide us by any means (forms, emails, telephone, contracts, etc.) and after reading it, freely decide whether you want us to process them. Additionally, it will serve to expand the information that we have previously provided to the interested parties, in the informative clauses provided in the processes of collecting their personal data.   

Likewise, this policy aims to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data (hereinafter RGPD) and the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (hereinafter LOPDGDD).  

2. Who is responsible for the processing of your personal data? 

  • Identity – Entity: ASOCIACIÓN DE INVESTIGACIÓN DE MATERIALES PLÁSTICOS Y CONEXAS (PLASTIC MATERIALS AND RELATED MATERIALS RESEARCH ASSOCIATION) 
  • CIF/NIF: G46714853 
  • Postal address: València Parc Tecnològic. C/Gustave Eiffel, 4. 46980 Paterna (València) Spain.
  • Phone: +34 961 366 040 
  • E-mail: dpo@aimplas.es 
  • Corporate Social Purpose: Instituto Tecnológico del Plástico 
  • Website: https://www.aimplas.es/ 
  • Registered details: Registered in the Register of Associations Nº 97.210 (Reg. Nac. Asociaciones Mº del Interior); Nº 40 (Registro de Centros Tecnológicos y centros de Apoyo a la de Innovación).  

 

3. How can you contact the Data Protection Officer? 

Our entity has named a Data Protection Officer at the General Registry of the Spanish Data Protection Agency, to whom the interested parties may address their complaints or doubts about how our entity is processing their personal data. You may contact him in writing, stating the name of our entity or trade name, followed by your complaint or query to: 

BUSINESS ADAPTER, S.L. 

Ronda Guglielmo Marconi, 11, 26, (Technology Park) 46980 Paterna (Valencia). 

Data subject contact form 

 4. What personal data will we process and how do we obtain it? 

For the development of our business activity, it is essential to process personal data whose collection can be done by digital means (e.g. email, web forms or questionnaires), by filling out paper documents (e.g. contracts or forms) or through face-to-face or telephone conversations and in any of these cases the data will be processed in a fair, lawful and transparent manner. 

The categories of data that our entity will process about the interested parties are: 

  • Identification data: name and surname, ID card or equivalent document, image, voice and signature (handwritten or digital). 
  • Contact details: telephone, email, postal address. 
  • Identification codes: identifiers for remote access to our website (e.g. virtual classroom). 
  • Commercial data: contract number, type of service, budgets, commercial conditions, management and consumption history, results of contacts been made (telephone, email, messaging and other communication channels). 
  • Accounting data: control of income and expenses, invoicing data. 
  • Banking data: bank accounts and credit cards. 
  • Transaction of goods and services: transfers and direct debits, amounts and concepts. 
  • Curricular data: academic level, educational background. 
  • Psychotechnical/ psychological tests: personality results, skills and aptitudes. 
  • Financial data: payment conditions, payment management. 
  • Navigation data: analysis of the time spent on our website, pages visited, demographic data (e.g. age, gender). 

Our company will not ask you to provide special category data (e.g. health data, ethnic origin, political opinions or religious beliefs), but in the event that it is necessary to process them, we will inform you and ask for your prior express consent. 

Consequently, the data requested will be adequate, relevant, limited to those strictly necessary and indispensable, processed only by personnel and/or collaborators authorized by our entity, who will have signed a confidentiality agreement and undertake to comply with the necessary security standards to ensure the confidentiality, integrity and availability of the data processed and other legal requirements established in the RGPD. Therefore, they will be processed in accordance with the law. 

The data to be processed are provided by the data subject him/herself or by his/her legal representative, although it may be the case that we delegate some functions to certain collaborators and they are responsible for collecting your data, but they will always be processed with your prior and express consent. 

In the event that a data subject does not provide the data we request or provides incomplete or incorrect data, it will not be possible to fulfill and maintain the relationship with them. 

The categories of data that we may process about a person will depend on the relationship with our company, as shown below: 

4.1. Clients and Associated Entities: 

We will process identification data, contact, commercial, accounting, banking, transaction of goods and services, financial data and may be collected only if you provide them to us at the time of contracting services, although they may also be collected by any entity to which we have temporarily joined (e.g. UTE) to undertake joint projects. 

4.2. Information requesters: 

Whether the information requested is by telephone or in writing (e.g. email or web forms) we will request and process your identification, contact and commercial data. 

4.3. Suppliers and partners: 

Identification, contact, commercial, accounting, banking, transaction of goods and services and financial data will be processed. These data may be processed during all stages of the business relationship. 

4.4. Participants 

From the participants of our training actions, identification, curricular, contact, commercial, accounting, banking, transaction of goods and services, financial data will be processed and may be collected only if you provide them to us at the time of contracting services, although they may also be collected by any entity to which we have temporarily joined (e.g. UTE) to undertake joint projects. More information is available in the Training policy. 

4.5. Job applicants 

For this category of interested parties, curricular, identification, contact and other data related to their professional or personal characteristics will be processed, when they send us their application by any means (e.g. in person, email, web forms), they may also be collected in recruitment interviews (in person or by videoconference), they may even send us their job application through a partner to whom we have assigned certain functions. All candidates are required to take a psycho-technical/psychological test. For more information, please refer to our Job application policy. 

4.6. Social media users 

We are present in different social media and we may process identification, contact, commercial and other data that the user enables to be displayed or shared with other users of the social media, including curricular data (e.g. LinkedIn). For more information, please see our Training policy. 

4.7. Subscribers: 

In the subscription forms to our newsletters an email address is requested.  

4.8. Complainants:  

We will process data of an identifying nature, contact and personal information about yourself or third parties who want to let us know, related to the claim that you send us. 

4.9. Whistleblowers: 

Through our internal whistleblower channel, whistleblowers may make complaints anonymously, but may also voluntarily provide us with identifying and contact data, as well as other personal information of their own or of third parties related to the complaint, as provided for in Law 2/2023 of February 20, on the protection of persons who report regulatory violations and the fight against corruption. More information in the Whistleblower Channel. 

4.10. Visitors: 

Identification and contact data will be processed, being collected when they are provided to us by the interested party when accessing our facilities or when your interlocutor in our entity, provides them to us to allow access to these. 

4.11. Web users: 

When visiting our website and only if expressly authorized by the user, analytical data may be collected (e.g. time of visit or pages viewed) including demographic data (e.g. gender, age, country or language). For more information visit our
Cookies policy. 

4.12. More information for interested parties: 

The information legally established in the corresponding informative clauses included in the different means of data collection will be made available to the interested parties, so that you freely and expressly decide if you want the personal data requested, to be processed by our entity. 

All categories and types of personal data processed will be duly identified in the corresponding processing activities owned by our company. 

5. What will your data be processed for? 

In general, the purpose of the processing of personal data carried out by our company is the fulfillment and maintenance of the relationship with different groups of people, such as clients or suppliers. Also with other people who contact us proactively through our web forms, by telephone or in person, by email or post, as would be the case of job applicants or information seekers, users of our website/blog or social networks and interested parties in general.  

Depending on this relationship the treatment of your data has different purposes and that with enunciative and not limiting character, we detail them as follows: 

5.1 Clients and associated entities: 

Your personal data will be processed to identify you, fulfill and maintain the pre-contractual and contractual relationship including the sending of commercial communications by different means, answer queries, perform quality controls and commercial statistics, to manage the contracting and provision of our services, for accounting and billing management, the transaction of goods and services, the management of collections, management of incidents, claims and exercise of rights, management of training bonuses, carrying out quality controls, consultations on economic solvency, as well as for other purposes to which we are obliged to comply with this relationship, the laws to which we are subject and to comply with our legitimate interests. 

5.2. Information requesters:  

We will process your personal data to fulfill your requests for general information, to identify you, to send or deliver quotations and information about goods and services of interest to you, including in our reply (verbal, written or digital) commercial information related to the request. We will also make follow-up contacts, by different means, to know the decisions taken with respect to the commercial proposals that we have sent you. 

5.3. Suppliers and partners:  

Your personal data will be processed for the purpose of maintaining the business relationship either for the request of quotations, for the purchase of goods or contracting of services, to identify you, for accounting management, perform transaction of goods and services, as well as for other purposes necessary to comply with such relationship, with our legal obligations and legitimate interests.   

5.4. Participants: 

The personal data of the participants in our training activities or events, will be processed to identify, fulfill and maintain the pre-contractual and contractual relationship including sending commercial communications by different means, answer queries, perform quality control and business statistics, to register and provide training / events among other related managements, for the publication of images to advertise our actions, for accounting and billing management, transaction of goods and services, payment management, incident management, claims and exercise of rights, as well as for other purposes to which we are obliged to comply with this relationship, the laws to which we are subject and to comply with our legitimate interests. 

Through the Virtual Classroom you can access your contracted training and your student profile, which includes additional information related to your training activities. More information is available in the Training policy. 

5.5. Job applicants:  

Your data will be processed to include you in our recruitment processes and job board, to identify you, as well as to contact you and inform you about vacancies, coordination of interviews and other matters related to your application. Through the psycho-technical/psychological tests that all candidates take, we will analyze the results in order to fit the future employee in the right work team, minimize labor conflicts, among other issues. For more information, please refer to our Job application policy. 

5.6. Social media users:  

We will treat your personal data to maintain the relationship as users of the same social media network, to identify you, to contact you, to share news and other personal data that you allow to share with the rest of the social media network members. For more information see our Social media policy. 

5.7. Subscribers:  

Your data will be processed to send you by email our newsletters or advertising, to identify you and to process the cancellation of these mailings if requested. 

5.8. Complainants:  

Personal data will be processed to identify you, manage your complaint and contact you about the status of your complaint, in addition to complying with our legal obligations and legitimate interests. 

5.9. Whistleblowers: 

The personal data you choose to provide us in your claim, will be processed to register, manage your claim, as well as to identify you and contact you (except if the claim is anonymous) for the acknowledgement of receipt of your claim and to keep you informed about the status of our investigations within the deadlines and terms established in the Law 2/2023, of February 20. Similarly, we may process your data based on our legitimate interests and whenever it is necessary to comply with other legal obligations to which we are subject. More information in the Whistleblower Channel. 

5.10. Visitors:  

The data of visitors to our facilities, will be processed to identify you, to comply with our obligations in terms of prevention of labor risks and for security issues and access control to our facilities. 

5.11. Web users: 

Data may also be processed for different purposes (e.g. analysis of visits) by accepting the use of cookies when visiting our website. For more information visit our
Cookies policy. 

5.12. Further information for the interested parties: 

We will make available to the interested parties, the information legally established in the corresponding informative clauses included in the different means of data collection, (e.g. forms) and in others that we will make available to you (e.g. badges, invoices, legal notices, etc.), so that you freely and expressly decide whether you want the personal data requested to be processed by our entity. 

If you do not provide the data requested by us or if incomplete or incorrect data is provided, it will not be possible to process your request for information, purchase or sale of goods or the contracting of our services. 

The data will not be processed further or for purposes other than those accepted by the interested parties.  

The purposes that justify the processing of personal data will be duly identified in the corresponding processing activities owned by our company. 

6. Why do we process your data (legitimation)? 

The processing of your personal data by our company is carried out on one or more of the following legitimate bases: 

  1. When you offer us your express, free, informed and unequivocal consent, after being informed at the time of collecting your data and more extensively with this privacy policy, that after reading this and being in agreement, you can voluntarily authorize us to process your data for one or more purposes, by checking the boxes provided for this purpose in our web forms, through your verbal consent (will involve voice recording) or by signing the informative clauses that we provide you at all times when requesting your personal data.
  2. For the execution of a contract to which you are a party or in which you have requested us to take pre-contractual measures. 
  3. When the processing is necessary for compliance with a legal obligation applicable to our entity.
  4. When the processing is necessary for the fulfillment of legitimate interests pursued by our company or by a third party, provided that such interests do not override the interests or fundamental rights and freedoms of the data subject. In this regard, we inform that our entity has conducted an analysis weighing our legitimate interests with the rights and freedoms of the data subject, always respecting their fundamental rights. 

In the event that the user is under 14 years of age, it will be necessary to have the consent of parents, guardians or legal representative, to process their data. The user is solely responsible for the accuracy of the data he/she sends us. 

7. Data storage 

The personal data provided will be kept as long as we maintain the relationship with you and for the time necessary to fulfill the purpose for which your data has been collected.  

Once this relationship has ended, we will keep them blocked in those cases where it is necessary to keep them until the prescription of responsibilities for the sole purpose of claims or legal actions, as well as to comply with our legal obligations, for example: 

Interested parties  Sectoral scope  Legal basis  Retention period 
  • Clients  
  • Associated companies 
  • Suppliers 
Accounting  Art. 30.1 R.D. Commercial Code 
  • 6 years from the last entry 
  • Clients  
  • Associated companies 
  • Suppliers 
Tax  Art. 66 General Tax Law 58/2003 
  • General term: 4 years. 
  • In case of losses during the fiscal year: 10 years. 
  • Invoices: 5 years 
  • Employees 
Labor  Art. 21 of Royal Legislative Decree 5/2000- Social Order 
  • 4 years 
  • Job applicants 
Labor  AEPD Guide to employment relationships 
  • 1 year 
  • Employees 
Prevention of occupational hazards  Art. 4.3 of Royal Decree 5/2000- Social Order 
  • 5 years 
  • Visitantes 
Control of access to facilities  AEPD Instruction 1/1996 
  • 1 month 
  • Web users 
Use of cookies  Guide on the use of cookies of the AEPD 
  • 24 months maximum 
  • Clients 
  • Associated companies 
  • Suppliers 
  • Visitors 
  • Job applicants 
  • Employees  
Video monitoring  Art. 22.3 LOPDGDD- protection of personal data 
  • 1 month 
  • Clients 
  • Associated companies 
  • Participants 
User information in Internet service providers  Art. 5 of Law 25/2007- conservation of electronic communications data and public communications networks. 
  • 12 months since the communication was given. The data to be kept are those established in article 3 of the law. 
  • After consulting the operators, this period may be extended by regulation to a maximum of 2 years or a minimum of 6 months. 

 

  • Whistleblowers 
  • Involved parties 
Internal Whistleblower Channel Complaints  Art. 26.2 Law 2/2023- internal information systems. 

Art. 32.3 Law 2/2023- internal information systems. 

Art. 32.4 Law 2/2023- internal information systems 

  • In case the reported events have been under investigation, it will not exceed 10 years of storage. 

 

  • For the time necessary to decide whether to initiate an investigation into the events reported. If it is proven that the information provided or part of it is not truthful, it must be immediately deleted, unless such lack of truthfulness may constitute a criminal offense, in which case the information will be kept for the necessary time during the judicial proceedings. 

 

  • If the investigation is not initiated within 3 months of receipt of the complaint, the information must be deleted. 

 

 

8. Profiling 

We do not create profiles using your personal data. However, if we do, we will inform you and ask for your prior permission to do so. 

You also have the right to object to this type of processing at any time by sending an email to dpo@aimplas.es. 

9. Transfer of personal data 

As a general rule, our organization does not disclose personal data to third parties, although in some cases this may be necessary: 

If you are an associate, client, participant or supplier, your personal data may be disclosed to third parties as required by law (e.g. tax authorities). The same is true in cases and organizations where it is necessary to provide our services and pay invoices (e.g. banking institutions). In case of contracting subsidized training, personal data may be transferred to the State Foundation for Employment Training (Fundación Estatal para la Formación en el Empleo). 

In addition, as an associated company, participant, client or supplier, your personal data may be processed by certain suppliers to whom we delegate some of our obligations (e.g. accounting consultants). All data processors have signed a data processing contract and have agreed to comply with the same security measures implemented by our organization, and to be subject to professional secrecy and confidentiality regarding the personal data processed, among other obligations in the area of personal data protection. 

If you are a job applicant, your data will not be disclosed to third parties, unless we are legally obliged to do so. Although they may be transferred to other companies in our group of companies, if you have previously authorized us to do so. 

If you are an information requestor or user of our website, your data will not be disclosed to third parties, unless we are legally obliged to do so. 

If you are a complainant, your data may be lawfully processed by persons other than those responsible for the internal information system, and may be communicated to third parties, when necessary for the adoption of corrective measures in our organization or the processing of disciplinary or criminal proceedings, if any, as appropriate (art. 32.2 Law 2/2023).  

In general terms, we may transfer your personal data to the Judges, Courts, the Public Prosecutor’s Office and/or the competent Public Administrations in the event of possible claims when we are obliged to do so. 

10. International transfer of data 

In the case of transfers to other organizations or other countries outside the European Economic Area (EEA), we will inform you and ask for your express prior consent. 

11. Security measures 

Our organization has implemented all the necessary technical and organizational measures to protect the personal data processed and to prevent their loss, theft or unauthorized use. 

These measures have been created based on the type of data processed and the purposes for which they are processed. These measures are regularly verified in our internal controls of data protection compliance and by external audits. 

12. Rights of data subjects 

You, as the owner of your personal data and acting on your own behalf or through your legal representative (e.g. persons under 14 years of age) can contact our entity at any time and ask us to exercise your rights regarding the protection of personal data. 

We explain what these rights are: 

Access Rights: 

You have the right to know and ask us at any time to obtain the following information: 

  • Whether or not we are processing your personal data. 
  • The purposes of the processing, as well as the categories of personal data being processed. 
  • The origin of your data, if not provided by you. 
  • The recipients or categories of recipients to whom your personal data have been or will be disclosed, including, where applicable, recipients in third parties or international organisations. 
  • Information on appropriate safeguards concerning the transfer of your data to a third country or international organisation, where applicable. 
  • The expected retention period, or if this is not possible, the criteria for determining this period. 
  • If there are automated decisions, including profiling, meaningful information on the logic applied, as well as the significance and expected consequences of such processing. 
  • A copy of your personal data being processed. 

Correction Right: 

Request us to rectify your personal data when it is inaccurate, as well as to complete it when it is incomplete. 

Opposition right: 

You may object to our processing of your data when it is incorrect or no longer necessary. 

In the event that you act in the role of a reported person or person concerned by a complaint under Law 2/2023, you may not exercise your right to object, as it is presumed (upon proof to the contrary) that there are grounds that legitimate the processing of your personal data, in accordance with the provisions of article 31.4 of the Law. 

Deletion Right: 

Request us to delete your data, for any of the following reasons: 

  • Your data is no longer necessary for the purposes for which it was collected or processed. 
  • You did not give your consent for the processing of your data. 
  • When you have exercised your right to object. 
  • When the data have been processed unlawfully. 
  • When the data must be deleted in order to comply with a legal obligation. 

Right to restrict processing: 

You may request us to exercise this right where one or more of the following situations apply: 

  • When you question the accuracy of your data, for a period of time that allows the data controller to verify the accuracy of the data. 
  • When the processing is unlawful and you object to the deletion of your data and request instead the restriction of their use. 
  • When the data are no longer needed for the purposes of processing, but the data are needed by the data subject for the establishment, exercise or defense of claims. 
  • When you have objected to the processing pursuant to Article 21(1), while it is being verified whether the legitimate reasons of the controller prevail over the participating individuals. 

Portability Right: 

This refers to the right to obtain data relating to you, in a structured, commonly used and machine-readable format, and to transmit it to another data controller for further processing. 

The right not to be subject to automated decisions: 

The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on it or similarly significantly affects it in a similar way. 

To exercise any of your rights, you must write to us either by post to the following address: Calle Gustave Eiffel, 4, CP 46980 Paterna (Valencia), or by e-mail: dpo@aimplas.es, stating the rights you wish to exercise, accompanied by a copy of your ID card or equivalent document so that we know about whom we must provide the information requested and your contact details so that we can send you our reply. If you are acting on behalf of another person, you must provide proof of representation. 

If you have any suggestions or queries about the processing of your personal data, you can contact the data protection officer, indicating our company name or trade name to: 

BUSINESS ADAPTER, S.L. 

Ronda Guglielmo Marconi, 11, 26, (Parque Tecnológico) 46980 Paterna (Valencia). 

Data subject contact form. 

We inform you that you have the right to make a complaint to the Spanish Data Protection Agency at: C/ Jorge Juan, 6, 28001 Madrid or at www.aepd.es. 

13. Updating this policy 

We reserve the right to modify this Policy without prior notice. We therefore recommend that you consult it each time you visit our Website. 

Text updated on April 15, 2024