Your data will be processed in accordance with current legislation, specifically, with the provisions of Regulation (EU) 2016/679 of 27 April 2016 (GDPR) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data. It will also be processed pursuant to Organic Law 3/2018 of 5 December on the protection of personal data and the guarantee of digital rights.
1 Who is the controller?
If you or someone authorised by you has provided us with your data, we hereby inform you that SANTOS (the companies that operate commercially under this brand) are the controller. This data will be processed in accordance with the provisions in the current regulations on the protection of personal data.
There may be other controllers involved in the processing we carry out; in those cases, we will always inform you of the controller and their identification details.
We at SANTOS are committed to complying with the duty of secrecy, keeping personal data confidential and safe. To this end, we have taken the necessary measures to prevent its alteration, loss, unauthorised processing or access in accordance with the provisions of the Regulation.
SANTOS is made up of:
- SANTOS COCINA Y BAÑO, S.L.U. with tax ID code (CIF): ESB15383896
- SANTOS EQUIPAMIENTO DE INTERIORES, S.L.U. with tax ID code (CIF): ESB15515232
- SANTIAGO INTERIORES, S.L.U. with tax ID code (CIF): ESB15513260
- SCQ PLANNING, S.L. with tax ID code (CIF): ESB70415104
- SCQ PLATFORMS, S.L.U. with tax ID code (CIF): ESB70411400
- EBA FRANCE, SARLU. with tax ID number: FR93828684316
2 Where do we provide information?
3 What personal data do we process?
The personal data we process includes:
- Any data you voluntarily provide us with
- Data arising from the communications you maintain with us
- Your browsing information for online services (IP address or information from cookies or similar devices (please see our Cookies Policy on the website)
- Any information from publicly available sources, which we lawfully have access to
- Data arising from the contractual or pre-contractual relationship you maintain with us, including your image; in such cases, you will always be informed of the possibility of capturing your image
- Data that third parties provide us with about you, with a lawful basis for it or after obtaining your consent to it
- Third-party data you provide us with, with the consent of the third party in question
4 How do we process data?
At SANTOS, we always process your personal data strictly in compliance with current legislation. We would also like you to know that we have the appropriate technical and organisational means to ensure an optimal level of security. Through them, we can guarantee that only authorised individuals will have access to it, that we will keep it intact – preventing any deliberate or accidental loss – and that we have strengthened our data processing systems and services.
Nevertheless, due to the fact that SANTOS cannot guarantee the absolute impregnability of the Internet nor the complete absence of hackers or others that fraudulently access personal data, we undertake to notify you without any undue delay of any personal data breach that may pose a high risk to the rights and freedoms of natural persons. Pursuant to the provisions of Article 4 of the GDPR, a personal data breach is understood to be any security breach that leads to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such data.
The technical operations, arrangements and procedures that we carry out in an automated or non-automated way and that enable the collection, storage, modification, transfer and other actions on personal data are considered to be personal data processing activities.
5 What is the lawful basis for processing?
The lawful basis for the processing of personal data is the contractual or pre-contractual relationship, the employment relationship or any other lawful basis necessary for the processing of data, such as explicit consent from the data subject.
6 How do we manage electronic communications?
In accordance with the provisions of Law 34/2002 of 11 July on information society services and electronic commerce and Directive 2002/58/EC, we hereby inform you that you may receive commercial communications and information through this electronic communications system (e-mails, automated reply messages from forms and other communications systems) once you have given us your consent or when there are commercial communications about products or services that are similar to those that have been previously provided by the controller.
In case you do not wish to receive any communications or information of this nature, you can notify us of this through the same means by writing “OPT OUT OF COMMERCIAL COMMUNICATIONS” in the subject line so your personal data is removed from our database. Your request will be dealt with within one month from the date it was sent. If we do not receive a reply from you expressly stating otherwise, we will take this to mean that you agree to and authorise our company to continue sending you the aforementioned communications.
If you receive such communications by these means, we would like you to know that the messages are exclusively intended for the recipient and may contain privileged or confidential information. If you are not the intended recipient, we hereby inform you that any unauthorised use, disclosure and/or copying is strictly forbidden by current legislation.
7 How long will we store your data?
The personal data on natural persons which SANTOS have collected through any means will be kept provided the data subject does not request its erasure. Likewise, it will be kept for as long as the relationship that gave rise to the data processing activity remains, while abiding by the statutory retention periods at all times. At the end of this period, the personal data will be removed from all SANTOS systems.
8 Will your data be disclosed to third parties?
Personal data will not be assigned, transmitted or transferred, except for the cases already mentioned above, which are not a consequence of any legal obligation. If we are requested by the public authorities or the regional institutions to do so within the scope of the functions expressly attributed to them by law, your data will be transmitted.
If it is necessary to assign, transmit or transfer your personal data outside of the cases mentioned above, you will be notified of this beforehand so that you may, where applicable, grant your consent.
In order for us to get everything organised as well as run smooth operations and procedures that ensure good management, it may be necessary for SANTOS to engage the services of advisers, professionals or other service providers to process data according to our instructions.
Such processing by third parties will be regulated by a contract in writing or in any other form admissible by law which can prove that it has been entered into as well as its content. It will expressly state that the processor will process the data in accordance with our instructions, not use it for any purpose other than the one that appears in the contract and not disclose it to other parties, not even for its storage.
9 What rights do you have?
The data processing regulations grant you the following rights:
- Right of access: It is the User’s right to obtain confirmation about whether or not SANTOS EQUIPAMIENTO DE INTERIORES, S.L.U. is processing their personal data. Where that is the case, they can obtain information about their specific personal data and the processing activities that SANTOS EQUIPAMIENTO DE INTERIORES, S.L.U. have carried out, as well as any available information on the source of such data and the recipients to whom the data has been disclosed or will be disclosed.
- Right to rectification: It is the User’s right to rectify any personal data that is inaccurate or – taking into account the purposes of processing – incomplete.
- Right to erasure (“right to be forgotten”): It is the User’s right, unless otherwise provided by law, to obtain the erasure of their personal data when it is no longer necessary for the purposes for which it was collected or otherwise processed; the data subject withdraws their consent for processing and there is no other lawful basis for it; the data subject objects to the processing and there is no other lawful basis to continue with it; the personal data has been unlawfully processed; the personal data must be erased to comply with a legal obligation; or the personal data was obtained in relation to a direct offer of information society services to a minor under the age of 14. Aside from erasing the data, the Controller, taking into account the available technology and the cost of its implementation, must take reasonable measures to inform the controllers that are processing personal data of the data subject’s request to erase any link to such personal data.
- Right to restrict processing: It is the User’s right 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 data has been unlawfully processed; the Controller no longer needs the personal data but the User needs it to file a claim; and when they have objected to the processing of their data.
- Right to data portability: In case processing is done by automated means, the User will have the right to receive their personal data from the Controller in a structured, commonly used and machine-readable format, as well as request its transmission directly to another controller. Whenever it is technically feasible, the Controller will directly transfer such data to another controller.
- Right to object: It is the User’s right to not have their personal data processed or for SANTOS EQUIPAMIENTO DE INTERIORES, S.L.U. to stop processing it.
- Right not to be subject to a decision based solely on automated processing, including profiling: It is the User’s right to not be subject to automated individual decision-making, including profiling, unless otherwise provided for by current legislation.
If you want more information on the processing of your data, rectify any data that is inaccurate, object to and/or restrict any type of processing that you do not consider necessary, or request processing to stop when the data is no longer necessary, you may post a letter to SANTOS at: Rúa do Restollal, 32, Planta 1ª – 15702 – Santiago de Compostela (A Coruña); Deseiro, s/n | Sergude – 15881 – Boqueixón (A Coruña); or send an e-mail to firstname.lastname@example.org.
- This communication must contain the following information: The User’s name and surname(s), the request they want to make, the address and supporting documentation.
- Rights may only be exercised by the Users themselves. Nevertheless, they may be exercised by an individual who is authorised to be the legal representative of the User. In this case, documentation proving such representation of the data subject must be provided.
We would also like to inform you that you may withdraw the consent given without this affecting the lawfulness of any processing that has already been done by sending your request to the same address provided in the paragraph above. In this case, you must attach a copy of your national identity card or passport to your request.
If you believe there is an issue or breach of the current regulations with regard to how your personal data is being processed, you have to the right to effective judicial protection and to file a claim with a competent supervisory authority, specifically in the State where you reside or work or where the alleged breach took place. For Spain, the competent supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/) – C/ Jorge Juan, 6 28001 – Madrid – FAX: +34 914483680 – TEL.: +34 901 100 099 – E-mail: email@example.com.
10 What is the purpose and the lawful basis for the processing of data and how long will the data be kept?
The purposes of the data processing activities carried out by some or all of the Controllers listed above are as follows:
SANTOS COCINA Y BAÑO, S.L.U. – SANTOS EQUIPAMIENTO DE INTERIORES, S.L.U. – SANTIAGO INTERIORES, S.L.U. – SCQ PLATFORMS, S.L.U. – SCQ PLANNING, S.L. – EBA FRANCE, SARLU.
PURPOSE OF THE PROCESSING
|Management of staff to formalise employment contracts, keep files under control and manage payroll||Contractual relationship5 years from the end of the contract||5 years from the end of the contract||All|
Tax and accounting management
|Processing necessary for compliance with tax and accounting obligations||Contractual relationship Legal obligation of the controller Overriding legitimate interest of the controller or third parties||5 years from the end of the contract The time necessary to comply with legal obligations||All|
|Processing of data in order to maintain communications with data subjects||Contractual relationship Overriding legitimate interest of the controller or third parties Explicit consent from the data subject||5 years from the end of the contract Until request for erasure and/or objection by the data subject Until it is no longer used||All|
Occupational health and safety
|Compliance with current legislation on occupational health and safety and health surveillance||Contractual relationship Legal obligation of the controller||Until the end of the contractual relationship The period legally established by the specific SANTOS EQUIPAMIENTO DE INTERIORES, S.L.U. regulations SANTIAGO INTERIORES, S.L.U. SCQ PLATFORMS, S.L.U. SCQ PLANNING, S.L.||SANTOS EQUIPAMIENTO DE INTERIORES, S.L.U. SANTIAGO INTERIORES, S.L.U. SCQ PLATFORMS, S.L.U.|
|Capturing of images through video surveillance system and/or alarm system with image capture, to protect the company’s assets||Overriding legitimate interest of the controller or third parties||1 month||SANTOS EQUIPAMIENTO DE INTERIORES, S.L.U.|
Job candidate management
|Staff recruitment and hiring through the management of CVs, face-to-face interviews and assessment tests||Vital interests of the data subject or other individuals Explicit consent from the data subject||Maximum of 1 year||All|
Communication of information and notifications
|Dissemination of activities and notification of relevant information related to the company’s activities||Overriding legitimate interest of the controller or third parties Explicit consent from the data subject||Until request for erasure and/or objection by the data subject||All|
|Processing of images and/or videos for dissemination in the media and social media and promotion of activities||Explicit consent from the data subject||Until request for erasure and/or objection by the data subject Until it is no longer used||SANTOS EQUIPAMIENTO DE INTERIORES, S.L.U.SANTIAGO INTERIORES, S.L.U.|
|Processing of data necessary for the maintenance of the business/contractual relationship with customers, billing, after-sales service, the sending of offers and advertising and building loyalty.||Contractual relationship Commercial relationship||5 years from the end of the contract The period legally established by specific regulations||All|
Sending of advertising
|Sending of commercial information, notifications about actions and events or interest, deals and information on products and services to customers and potential customers.||Explicit consent from the data subject||Until request for erasure and/or objection by the data subject Until it is no longer used||All|
|Tracking employee attendance at work (holidays, absences, time tracking)||Contractual relationship Legal obligation of the controller Overriding legitimate interest of the controller or third parties||Until the end of the contractual relationship||SANTOS EQUIPAMIENTO DE INTERIORES, S.L.U.SANTIAGO INTERIORES, S.L.U.SCQ PLATFORMS, S.L.U.|
|Analysis, evaluation, hiring, order management and supplier payment management||Contractual relationship||5 years from the end of the contract The period legally established by specific regulations||All|
|Warranty management for the products sold for compliance with Royal Legislative Decree 1/2007||Legal obligation of the controller||The time necessary to comply with legal obligations||SANTOS EQUIPAMIENTO DE INTERIORES, S.L.U.SANTOS COCINA Y BAÑO, S.L.U.|