Personal Data Protection. Privacy Policy
1. Text of the Privacy Policy
Welcome to the Privacy Policy of GRUPO TUBACEX. In this document you will find information of interest regarding how GRUPO TUBACEX processes your personal data and the rights you have under 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 (GDPR) and Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).
Identity and contact details of the Controller
GRUPO TUBACEX is an industrial group founded in 1963, dedicated to the manufacture of seamless tubes in stainless steel and high nickel alloys and superalloys. For our management, we need to process personal data based on the treatments mentioned in the following chapter. You can see in detail who we are and our organizational structure at www.tubacex.com
The interested party may contact the entities belonging to GRUPO TUBACEX through the email address gdpr@tubacex.com or the postal address Tres Cruces 8, 01400, Llodio (Álava-Spain) for any questions or needs they may have regarding data protection.
Processing of personal data
1.1 Shareholders
The entities belonging to GRUPO TUBACEX will process the data relating to shareholders and partners in order to manage and maintain the relationship with the shareholders, including the administrative management of the rights inherent to their status as shareholders, such as attendance at general meetings, the exercise of voting rights, the collection of dividends and other actions necessary for the management of their shareholding; comply with the legal obligations applicable to the Data Controller, facilitate the exercise of the information rights of shareholders and manage any queries or requests from them in relation to their shareholding; and send communications relating to the management of the shareholder status, including the calls for general meetings and other information relevant to shareholders.
Legal basis: The basis that legitimises the processing is compliance with the legal obligations applicable to the Data Controller (the corresponding GRUPO TUBACEX entity) in application of the provisions of Royal Legislative Decree 1/2010, of 2 July, approving the revised text of the Capital Companies Act.
Retention period: The data will be kept for the time necessary to fulfil the purposes for which they were collected, as well as to meet any legal liability that may arise from their processing. Subsequently, the data will be blocked and kept only at the disposal of the competent authorities during the limitation periods.
Recipients: Your data will not be communicated to third parties unless legally required to do so.
Rights: You may exercise your rights in terms of data protection as indicated in the “Exercise of Rights” section of this Privacy Policy.
1.2 Personnel selection.
The entities belonging to GRUPO TUBACEX will process the data relating to the candidates in order to manage the selection processes for GRUPO TUBACEX jobs.
Legal basis: The basis that legitimises the processing is the consent of the interested party in the case of the presentation of self-candidacies when there is no open selection process or in the application of pre-contractual measures when your data comes from a platform or selection company.
Conservation period: The data provided will be kept for the time strictly necessary to fulfil the intended purpose. Once this period has elapsed or you request deletion or revoke the consent granted to participate in this process, your personal data will be deleted:
Recipients: The data will be communicated between the Group entities if your profile is compatible with another available job in application of the provisions of CD 48 of the GDPR.
Rights: You may exercise your rights in relation to data protection as indicated in the “Exercise of Rights” section of this Privacy Policy.
1.3 Management of clients and suppliers
The entities belonging to GRUPO TUBACEX will process the data relating to clients and suppliers in order to manage the commercial and contractual relationship with the clients and suppliers respectively; as well as to manage the contact details of the contact persons linked to Grupo Tubacex for commercial, business or marketing purposes, as well as institutional relations.
Legal basis: The basis that legitimises the processing is compliance with contractual obligations and the legitimate interest in relation to the contact details
Retention period: Personal data will be kept as long as the contractual relationship between the parties is maintained. After the end of the relationship, the data will be blocked and kept for the applicable legal prescription periods, with the sole purpose of complying with legal obligations or meeting possible liabilities.
Recipients: Your data may be communicated between the entities of the Group for administrative purposes in application of CD 48 of the GDPR.
Rights: You may exercise your rights in relation to data protection as indicated in the “Exercise of Rights” section of this Privacy Policy.
1.4 Commercial communications
The entities belonging to GRUPO TUBACEX will process the data to send commercial communications.
Legal basis: The basis that legitimises the processing is consent or legitimate interest in application of article 21.2 of the LSSI.
Storage period: Personal data will be kept indefinitely until you revoke your consent, object to the processing or request the deletion of your data.
International transfers: the user is informed that the commercial communications they request or if they have not objected to receiving them in the event that legitimate interest operates, will be sent using the tool [Mailchimp, managed by the company The Rocket Science Group LLC] whose servers are located in the United States, a country whose legislation does not offer a level of data protection equivalent to that of Europe; However, adequate data protection guarantees are provided by signing the Standard Contractual Clauses approved by Decision 2021/914/EU of the European Commission.
Rights: The interested party has the right to revoke at any time the consent given for the sending of commercial communications by simply notifying GRUPO TUBACEX that they do not wish to continue receiving commercial communications. To do so, the interested party may click on the link included in each commercial communication, cancelling the sending of electronic commercial communications, or revoke their consent by sending a communication to the email address: gdpr@tubacex.com.
In any case, entities belonging to GRUPO TUBACEX carry out other types of processing that are not detailed in this Privacy Policy, which are reported at the appropriate time.
Exercise of rights
We inform you that you may exercise the following rights:
- Right of access to your personal data to know which are being processed;
- Right to rectification of any inaccurate personal data;
- Right to deletion of your personal data, when this is possible;
- Right to request the limitation of the processing of your personal data when the accuracy, legality or necessity of the processing of the data is doubtful, in which case, we may retain the data for the exercise or defence of claims.
- Right to object to the processing of your personal data, when the legal basis that enables us to process it is legitimate interest. GRUPO TUBACEX will stop processing your data unless it has a compelling legitimate interest or for the formulation, exercise or defence of claims.
- Right to the portability of your data, when the legal basis that enables us to process it as indicated is your consent.
These rights may be exercised free of charge by the interested party, and where appropriate, by their representative, by means of a written request addressed to gdpr@tubacex.com.
In addition to the above rights, the interested party shall have the right to withdraw the consent given at any time without such withdrawal of consent affecting the lawfulness of the processing prior to the withdrawal of consent. The entities belonging to GRUPO TUBACEX may continue to process the data of the interested party to the extent permitted by applicable law.
The entities belonging to GRUPO TUBACEX remind the interested party that they have the right to file a complaint with the Spanish Data Protection Agency if they consider that a violation of data protection legislation has been committed with respect to the processing of their personal data.
What security measures do we have in place?
The entities belonging to GRUPO TUBACEX are committed to fulfilling their obligation to keep personal data confidential and to safeguard it, and will take the necessary measures to prevent its alteration, loss, processing or unauthorized access, in accordance with the provisions of applicable regulations.
The entities belonging to GRUPO TUBACEX have implemented the necessary technical and organizational security measures to guarantee the security of your personal data and prevent its alteration, loss and unauthorized processing and/or access, taking into account the state of the technology, the nature of the data stored and the risks to which they are exposed, whether they come from human action or from the physical or natural environment, in accordance with the provisions of applicable regulations.
Confidentiality
The personal data that we may collect through the website or through the various communications that we maintain with you will be treated confidentially, and we undertake to keep them secret in accordance with the provisions of the applicable legislation.
Links to other websites
This website may include hyperlinks to other sites that are not operated or controlled by GRUPO TUBACEX. Therefore, GRUPO TUBACEX does not guarantee, nor is it responsible for, the legality, reliability, usefulness, veracity and timeliness of the content of such websites or their privacy practices. Please, before providing your personal information to these websites outside of GRUPO TUBACEX, bear in mind that their compliance with data protection may differ from ours.
Update of the privacy policy
The content of the data protection policy may be subject to modification to adapt it to legislative changes that may occur, as well as to criteria and positions issued by the control authorities. In any case, any modification to the Privacy Policy will be duly notified to the Affected Party so that he/she is informed of the changes made in the processing of his/her personal data and, if the applicable regulations so require, the Affected Party may give his/her consent.