This Policy applies to the Inbonis websites (www.inbonis.com, www.inbonis.com/es, www.inbonis.com/fr), (collectively referred to as the “Inbonis Websites”).
In accordance with applicable laws and regulations, the Policy explains: (i) what personal data we collect and how we collect it; (ii) how we use your personal data; (iii) who can access personal data and for how long it is kept; (iv) the transfer and communication of personal data to third parties; (v) the security and confidentiality applied to personal data; (vi) your rights with respect to your personal data; and (vii) those responsible for this Policy.
Data Collection. When you visit the Inbonis Websites, the type of information we collect is: (i) Personal Identity Data (first and last name); (ii) Professional Data (professional title, department, company name); (iii) Contact Data (telephone and fax numbers, email address); (iv) Location Data (IP address, postal address, work address) and (v) Login Data (cookies).
INBONIS obtains its data from the following sources:
- The information you provide to us when you contract and/or maintain products and/or services with us, both directly and indirectly, such as: (i) You fill in an information request or documentation download forms on the INBONIS Websites; (ii) You use some of the various means of contact available on the Inbonis Websites (iii) You provide us with your contact information during a trade fair or similar event to be contacted at a later date (iv) You subscribe to the Inbonis blog; (v) You or your company sign a service contract with Inbonis or register a product (vi) You submit a job application to the Inbonis Human Resources department and we also collect personal data with your consent when you browse the Inbonis Websites using Internet technologies, including “cookies. “
- External sources of information, such as official newspapers and gazettes, public registers, government resolutions, telephone directories, lists of persons belonging to professional associations, official lists for the prevention of fraud, social networks and the Internet, as well as third party companies to which you have given your consent for the transfer of their data to credit, financial and insurance institutions.
In accordance with the EU General Data Protection Regulation n. 679/2016 (GDPR) and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights, INBONIS will collect and process the personal data of Registered Users by automated means, in order to respond to Registered Users’ request for access to INBONIS Services. Contact between INBONIS and Registered Users will be made by remote communication, for which their consent is requested via the Website. The consent of Registered Users to this effect is mandatory and, without it, it will be impossible for INBONIS to respond to the request and provide access to its Services. Consent for the sending of advertising, commercial and information material related to INBONIS is not mandatory and Registered Users can access the same services without having to provide their data for this purpose.
We only use your personal data to carry out the process for which it was collected, namely to: (i) Publish your credit rating on the Inbonis website and where appropriate allow access to public data by third parties; (ii) Respond to your requests for information or documentation, based on your consent; (iii) Manage any type of request, suggestion or enquiry about our professional services made to us by interested persons; (iv) To carry out commercial communications or other marketing activities, including the publication of newsletters, product information and invitations to activities or events, articles of interest and general information about our services, using your consent as a basis for legitimisation; (v) To manage data provided by job candidates, based on your consent; (vi) To send promotional communications by electronic means and newsletters: Processing of your data for the purpose of informing you about our services, offers, promotions and articles or content (newsletter, e-book), which may be of interest to you, via electronic (e-mail, SMS, Whatsapp) and/or telephone. (vii) To send information regarding your qualification and the Inbonis products that you or your company have purchased, using our legitimate interest as a legal basis; and (viii) To personalise and facilitate your browsing of the Inbonis Websites, based on your consent.
Registered Users’ personal data will be processed appropriately and with the utmost confidentiality in order to guarantee the development, fulfilment and control of the freely accepted contractual relationship and may be communicated exclusively to members of the INBONIS Group for the same purposes as indicated above.
In accordance with the provisions of the GDPR, and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights, Registered Users have the following rights: access, rectification, deletion or cancellation of personal data, the right to oppose processing, the right to limit the processing of their data, as well as the right to data portability. In addition, Registered Users have the right to revoke their consent at any time, without affecting the lawfulness of the processing based on the consent prior to such revocation.
Personal data will be stored by INBONIS until the Registered User decides to withdraw his/her consent. Consent may be revoked at any time by writing to the following email address: firstname.lastname@example.org. Any requests and any questions regarding the processing of Registered Users’ personal data can be sent to the same contact address.
In accordance with the provisions of the RGPD, INBONIS provides the User with basic information on data protection regarding the processing of their data:
- Controller: INBONIS S.A. CIF: B87186177. Address: SPAIN: Plaza de la Lealtad, 2, CP. 28014, Madrid FRANCE: Bourrienne 58, rue d’Hauteville 75010, Paris Tel.: +34 912772431 Email: email@example.com.
- Purpose: Maintenance of the contractual relationship established between the parties, the management, administration, provision of the service contracted in each case or the management of the product purchased, the extension and improvement of the services provided and the adaptation of the same to the preferences of the Registered User.
A necessary part of the maintenance of the contractual relationship is the complete recording, by means of any technically valid support for this purpose, of the telephone and/or telematic communications produced or derived from the use of any service provided by INBONIS, in order to be able to accredit the completion of any procedure relating to the request and contracting of said services, as well as to be able to deal with any claims and/or incidents that may arise, and the aforementioned recordings may be used as evidence in any legal or arbitration proceedings that may arise directly or indirectly between the two parties. In any case, the Registered User may obtain a copy of the aforementioned recordings, if so requested.
Likewise, your data may also be used for the consented sending of technical or operational information about INBONIS products and services or those of related entities.
In addition, INBONIS may use your data anonymously to carry out statistical monitoring of its Registered User service, considering the existence of a legitimate interest in the continuous improvement of internal response processes.
Legitimisation: The legal basis for the processing of the data is the consent of the interested parties for the processing and management of any request for information or consultation on our professional services, as well as for the sending of commercial communications carried out by INBONIS S.A.
INBONIS is also legitimised to process your data as the party responsible for such processing on the basis of the management, development and fulfilment of the contractual relationship, and therefore also has a legitimate interest in certain data transfers and the provision of services with third parties as they are necessary to carry out the service contracted by the Registered User. In any case, the consent of the interested party is required with regard to the sending of commercial communications or the transfer of data to third parties for commercial purposes. This consent may be revoked at any time by sending an e-mail to the following address: firstname.lastname@example.org.
Access: data provided to INBONIS by any means (website, e-mail, paper forms, and/or any other document) will be incorporated into a file owned by INBONIS S.A. Access to personal data is strictly reserved to Inbonis employees who need to access them in order to process them. These persons are subject to strict confidentiality obligations and may be subject to disciplinary sanctions, up to and including dismissal, in case of non-compliance with these obligations.
Recipients: Official bodies when there is a legal obligation, and eventually third parties or entities interested in accessing your personal data in order to provide the contracted services and other third parties for sending commercial information, subject to prior consent. If desired, the Registered User may request a complete list of the categories of suppliers who will have access to their data at email@example.com.
As part of our international operations, we may receive personal data from third party partners and transfer your personal data to countries outside the European Union while ensuring the level of data protection. Any transfer of your personal data by us outside the European Union is ensured by the signing of standard contractual clauses in order to protect your data in accordance with the requirements of the European regulation.
For the execution of certain processes, our subsidiaries, partners and suppliers may access personal data that we have collected, for the purposes of providing Inbonis services, marketing and advertising relating to our services.
In this regard, INBONIS follows strict criteria for the selection of service providers in order to comply with its data protection obligations and undertakes to enter into a data processing agreement with them imposing, among others, the following obligations: to implement appropriate technical and organisational measures; to process personal data for the agreed purposes and only in accordance with INBONIS’s documented instructions; and to delete or return the data to INBONIS upon completion of the provision of the services.
Rights: Rights of access, rectification, deletion or cancellation of personal data, right to oppose the processing, right to limit the processing of their data, as well as the right to data portability, and to revoke their consent at any time via email: firstname.lastname@example.org or if you prefer, you can write to us at Plaza de la Libertad, 2 (28014), for the attention of Inbonis S.A., enclosing a photocopy of the data subject’s ID card.
Right of Access, Rectification and Deletion: Interested parties have the right to obtain confirmation as to whether or not INBONIS is processing personal data concerning them. Interested parties have the right to access their personal data, as well as to request the rectification of inaccurate data or, where appropriate, to request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
Right to Limitation and Opposition: In certain circumstances, data subjects may request the restriction of the processing of their data, in which case we will only retain it for the exercise or defence of claims. In certain circumstances and for reasons relating to their particular situation, data subjects may object to the processing of their data. INBONIS will cease to process the data, except for compelling legitimate reasons, or the exercise or defence of possible claims.
Origin of the data: The data will be provided exclusively by the Registered User.
Storage periods: Your data will be processed until the query is resolved and for as long as they are necessary to fulfil the purposes for which they were collected, unless otherwise provided by law, in accordance with the applicable legal and regulatory limits. They may subsequently be kept anonymously, for statistical purposes and to improve the quality of the service. Data collected from a form or a trade fair is stored for 3 years. Data relating to an applicant is stored for 2 years. Login data (cookies) are stored for one year. Data collected through a contract that you or your company has signed with Inbonis is kept for a period of 5 years from the end of the relationship.
If the holder cancels all the contracts signed with INBONIS, he/she may: either maintain the consent to carry out commercial actions, considering that he/she has chosen this option if he/she does not expressly revoke the consent, or revoke the consent to carry out commercial actions, in which case, we will cancel his/her data by blocking them.
With this blocking, INBONIS will not have access to your data and will only process them in order to make them available to the competent Public Administrations, Judges and Courts or the Public Prosecutor’s Office, for the attention of possible liabilities related to the processing of the data, in particular for the exercise and defence of claims before the Spanish Data Protection Agency. We will keep your data blocked for the periods provided for in the applicable provisions or, where appropriate, in the contractual relations maintained with INBONIS S.A., proceeding to the physical deletion of your data once these periods have elapsed.
Security: Inbonis implements all necessary security measures to protect personal data against unauthorised access and any unauthorised alteration, disclosure or destruction. In addition, all of our employees are aware of and have received training on this Policy.