Privacy policy

At APTIVA TALENTO, E.S.P.J., we understand that maintaining a transparent relationship with you is essential. Therefore, below we present our Privacy Policy, so that you are duly informed at all times about how we securely collect and process any data you provide to us.

Your data will be processed in accordance with current legislation and, specifically, in accordance with the provisions of Regulation (EU) 2016/679 of April 27, 2016 (GDPR) regarding the protection of natural persons with regard to the processing of personal data and the free movement of such data. This also applies to the Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights.

A careful reading of our Privacy Policy will provide you with the necessary information to know how we will handle the data you provide.

1. WHO IS THE DATA CONTROLLER FOR YOUR DATA?

If you, or an authorized person, have provided us with your data, we inform you that APTIVA TALENTO, E.S.P.J., with Tax ID (CIF): E75642744, is the Data Controller. This data will be processed in accordance with the provisions of current regulations on personal data protection.

It is possible that there are other controllers involved in the processing we carry out; in such cases, we will always inform you of who the data controller is, as well as their identification details.

The Website may include hyperlinks or links that allow access to third-party web pages other than aptivatalento.com, which are therefore not operated by APTIVA TALENTO, E.S.P.J.. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own processing and their own privacy practices.

At APTIVA TALENTO, E.S.P.J., we are committed to fulfilling the obligation of secrecy regarding personal data and the duty to safeguard it. To this end, we adopt the necessary measures to prevent its alteration, loss, unauthorized processing, or access, in accordance with the provisions of the Regulation.

2. WHERE DO WE PROVIDE INFORMATION?

At APTIVA TALENTO, E.S.P.J., we provide information through the website aptivatalento.com in the section corresponding to the privacy policy. Further information can be found in the "Legal Notice".

3. WHAT PERSONAL DATA DO WE PROCESS?

The personal data we process includes:

Those that you choose to provide to us voluntarily.
Data derived from communications you maintain with us.
Information corresponding to your own navigation in the case of Online Services (IP address or information derived from cookies or similar devices—you can view our Cookies Policy on the web).
Information available from publicly accessible sources to which we may legitimately access.
Data derived from the contractual or pre-contractual relationship you maintain with us, including your image, always informing you in this case of the possibility of capturing your image.
Data provided by third parties about you, provided there is a legitimate basis for it or your consent has been obtained.
Third-party data that you provide to us, with the prior consent of the third party in question.

You can consult more information in the record of processing activities section of this privacy policy.

4. HOW DO WE PROCESS THE DATA?

At APTIVA TALENTO, E.S.P.J., we always process your personal data in strict compliance with current legislation. Furthermore, we inform you that we have appropriate technical and organizational measures in place to guarantee an optimal level of security, thereby ensuring that only authorized persons will have access, that we will keep the data intact, avoiding any intentional or accidental loss, and that we have reinforced the data processing systems and services.

However, because APTIVA TALENTO, E.S.P.J. cannot guarantee the invulnerability of the internet or the total absence of hackers or others who may fraudulently access personal data, it undertakes to communicate to you without undue delay when a personal data security breach occurs that is likely to entail a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a personal data security breach is understood as any breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

The operations, management, and technical procedures that we carry out, whether automated or non-automated, and that enable the collection, storage, modification, transfer, and other actions on personal data, are considered personal data processing.

5. WHAT IS THE LAWFUL BASIS FOR PROCESSING?

The lawful basis for processing Personal Data will be that resulting from the contractual or pre-contractual relationship, the labor relationship, or any other required for data processing, such as express consent.

6. HOW DO WE MANAGE ELECTRONIC COMMUNICATIONS?

In accordance with the provisions of Law 34/2002 of July 11, on Information Society Services and Electronic Commerce, and Directive 2002/58/EC, we inform you that you may receive commercial communications and information through this electronic communication system (emails, automated form response messages, and other communication systems) when you have granted us your consent or if these are commercial communications regarding products or services similar to those previously provided by the data controller.

In the event that you do not wish to receive communications and information of this nature, you may notify us by this same means, indicating in the subject line "UNSUBSCRIBE FROM COMMERCIAL COMMUNICATIONS" so that your personal data can be removed from our database. Your request will be processed within a period of 1 month from its submission. In the event that we do not receive an express response from you, we will understand that you accept and authorize our entity to continue carrying out the aforementioned communications.

In the case of receiving such communications by these means, we inform you that the messages are addressed exclusively to the recipient and may contain privileged or confidential information. If you are not the intended recipient, we notify you that any unauthorized use, disclosure, and/or copying is prohibited under current legislation.

7. HOW LONG DO WE RETAIN YOUR DATA?

Personal data regarding natural persons collected by APTIVA TALENTO, E.S.P.J. through any means will be kept as long as the data subject does not request its erasure. Likewise, it will be kept as long as the relationship that originated the data processing is maintained, respecting in any case the legal retention periods. Once this period has concluded, the personal data will be deleted from all APTIVA TALENTO, E.S.P.J. systems.

8. WILL YOUR DATA BE DISCLOSED TO THIRD PARTIES?

There will be no assignment, transmission, or transfer of personal data, except for those already reported, that are not as a result of a legal obligation. If requested by the Public Administration or Regional Institutions within the scope of the functions expressly attributed to them by law, your data will be transmitted.

Should there be an assignment, transmission, or transfer of personal data outside the cases provided for above, you will be previously informed so that, if applicable, you may grant us your consent.

However, to organize ourselves correctly and have good operations and procedures that guarantee proper management, APTIVA TALENTO, E.S.P.J. may find it necessary to hire the services of advisors, professionals, or other service companies to process data under our instructions.

This processing on behalf of third parties is regulated in a contract established in writing or some other legally admitted form that allows proof of its conclusion and content, expressly specifying that the data processor will process the data according to our instructions and will not apply or use it for a purpose other than that appearing in said contract, nor will they communicate it, even for its preservation, to other persons.

9. WHAT ARE YOUR RIGHTS?

Data protection regulations grant you the following rights:

Right of access: The right of the User to obtain confirmation of whether or not APTIVA TALENTO, E.S.P.J. is processing their personal data and, if so, to obtain information about their specific personal data and the processing that APTIVA TALENTO, E.S.P.J. has carried out or is carrying out, as well as, among other things, the information available on the origin of said data and the recipients of the communications made or planned for them.
Right to rectification: The right of the User to have their personal data modified if it proves to be inaccurate or, taking into account the purposes of the processing, incomplete.
Right to erasure ("the right to be forgotten"): The right of the User, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when it is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn their consent to the processing and it does not have another legal basis; the User objects to the processing and there is no other legitimate reason to continue with it; the personal data has been processed unlawfully; the personal data must be erased in compliance with a legal obligation; or the personal data has been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to erasing the data, the Data Controller, taking into account the available technology and the cost of its application, must adopt reasonable measures to inform the controllers processing the personal data of the data subject's request to erase any link to that personal data.
Right to restriction of processing: The right of the User to restrict the processing of their personal data. The User has the right to obtain the restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it to make claims; and when the User has objected to the processing.
Right to data portability: In the event that processing is carried out by automated means, the User shall have the right to receive their personal data from the Data Controller in a structured, commonly used, and machine-readable format, and to transmit it to another data controller. Whenever technically possible, the Data Controller will directly transmit the data to that other controller.
Right to object: The right of the User not to have the processing of their personal data carried out or to cease the processing thereof by APTIVA TALENTO, E.S.P.J.
Right not to be subject to a decision based solely on automated processing, including profiling: The right of the User not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, unless current legislation establishes otherwise.

If you wish for more information regarding the processing of your data, to rectify inaccurate data, to object to and/or limit any processing you consider unnecessary, or to request the cancellation of processing when the data is no longer necessary, you may write to APTIVA TALENTO, E.S.P.J. at C/ Oporto, 19, 36201 - Vigo (Pontevedra) or by email to info@aptivatalento.com.

Such communication must reflect the following information: First and last name of the user, the request being made, the address, and the supporting documentation.
The exercise of rights must be performed by the user themselves. However, they may be executed by a person authorized as the legal representative of the authorized person. In such a case, documentation proving this representation of the data subject must be provided.

Furthermore, we want to inform you that you may withdraw the consent granted without affecting the lawfulness of the processing already carried out, by sending your request to the same address indicated in the previous paragraph. In this case, you must accompany your request with a copy of your ID card or document proving your identity.

In case you consider that there is a problem or violation of current regulations in the way your personal data is being processed, you will have the right to effective judicial protection and to file a complaint with a supervisory authority, in particular, in the State in which you have your habitual residence, place of work, or place of the alleged violation. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/) - C/ Jorge Juan, 6 28001-Madrid - FAX: 914483680- TEL: 901 100 099- E-mail: ciudadano@agpd.es

10. WHAT IS THE PURPOSE AND LAWFUL BASIS FOR DATA PROCESSING AND HOW LONG WILL THE DATA BE KEPT?

We detail below the purposes of the data processing carried out by any, or all, of the Data Controllers listed above.

PROCESSING ACTIVITY	PURPOSE OF PROCESSING	LAWFUL BASIS	RETENTION PERIOD
Labor management	Management of personnel for the formalization of a labor contract, record control, payroll management.	Contractual relationship	5 years from the termination of the contract
Tax and accounting management	Processing necessary for compliance with tax and accounting obligations.	Contractual relationship Legal obligation for the controller Prevailing legitimate interests	5 years from the termination of the contract The time necessary to respond to legal obligations
Contact management	Data processing to maintain communications with data subjects.	Contractual relationship Prevailing legitimate interests Express consent	5 years from the termination of the contract Until cancellation or objection Until the loss of its use
Occupational risk prevention	Compliance with current legislation regarding occupational risk prevention and health surveillance.	Contractual relationship Legal obligation for the controller	Until the end of the contractual relationship Legally established period
Candidate management	Personnel selection and provision of job positions, management of resumes, interviews, and tests.	Vital interests of the data subject Express consent	Once the period for which the appointment is requested has ended
Customer management	Maintenance of commercial relationship, billing, after-sales, promotions, and loyalty programs.	Contractual relationship Commercial relationship	5 years from the termination of the contract Legally established period
Labor control	Attendance control (vacations, absences, time tracking).	Contractual relationship Legal obligation Legitimate interests	Until the termination of the contractual relationship

11. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy, as well as accepts the processing of their personal data so that the Data Controller can proceed with it in the manner, during the periods, and for the purposes indicated. The use of the Website will imply the acceptance of its Privacy Policy.

APTIVA TALENTO, E.S.P.J. reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudencial, or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free movement of such data (GDPR) and to the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.