PRIVACY POLICY

Personal data protection policy

In compliance with the current regulations on data protection, consisting of the General Data Protection Regulation (EU Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016 – GDPR) and the Organic Law 3/2018 of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights (LOPDGDD), we inform you about our Personal Data Protection Policy.

Person in charge of processing personal data

Data controller the data controller is the legal entity that determines the purposes and means of processing personal data. In other words, the controller decides how and for what purposes personal data is processed.

For the purposes of this Personal Data Protection Policy, the data controller for personal data is:

Company name: Global Traktus SL

Tax ID: B27876531

Registered office: Calle Oporto 19, Vigo

Email: info@traktus.com

Telephone: +34 886405109

We also inform you that there are other joint data controllers for the processing of your data:

Company name: Micaton Ergonomics S.L

Tax ID: B27740893

Registered office: Avda. As Teixugueiras, 27 portal 2, 6ºH, 36212, Vigo

Email: micaton@micaton.com

Telephone: +34 886 317 613

You can obtain more information in the summary of the Joint Controller Agreement, which is also published on our website: https://handygymglobal.com

What personal data do we process and how do we protect it?

Personal data is any information about an identified or identifiable natural person (‘the data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

For the purposes set out in this Privacy Policy, the data controller collects and processes the personal data explained in each type of processing, which will depend on the different services you request or the contractual relationship you have with our entity.

Our organization is committed to treating your personal data with total confidentiality and to applying appropriate physical, technical and organizational security measures for the protection of your personal data.

You guarantee and are responsible, in any case, for the truthfulness, accuracy, validity and authenticity of the personal data provided and undertake to keep them duly updated.

Processing of data of “Customers and Suppliers”

1. What type of personal data do we process?

Identification data: name and surname, ID card number, address, telephone number, email address.

Financial data: bank account.

Academic and professional data: profession, position, experience, qualifications.

Data relating to transactions: products and services provided.

2. For what purpose do we process your personal data?

We process the personal data you provide us with for the management of our commercial relationship, accounting, administrative and billing management, as well as tax obligations.

The personal data provided will be kept for as long as the commercial relationship is maintained. If you decide to cancel your personal data, it may be kept in our databases for the periods provided for by the legislation in order to comply with tax and accounting obligations, and will be deleted once these legal periods or those applicable have expired.

In accordance with article 1964 of the Civil Code, actions arising from a contractual obligation prescribe after 5 years, so this will be the generic period for the retention of your data.

3. What is the legal basis for the processing of your data?

The legal basis for the processing of your data is the execution of a contract or even the adoption of pre-contractual measures, as well as compliance with a legal obligation of the controller.

4. Who will your data be communicated to?

Your personal data will not be transferred to any entity, except those that are necessary to public bodies by legal obligation.

There are processors who may carry out processing on our behalf and on our behalf, such as accounting and tax advisory services.

No international transfers of personal data have been planned.

Processing of data for “Contacts and potential clients”

1. What type of personal data do we process?

Identifying information: email address.

2. What is the purpose of processing your personal data?

We process the personal data provided in the contact form for the management of commercial contacts and potential clients’ data.

The personal data provided will be kept until opposition to processing is communicated. If you decide to cancel your personal data, it will be deleted from our contact database.

3. What is the legal basis for processing your data?

The legal basis for processing your data is the express consent requested from you.

4. Who will your data be communicated to?

Your personal data will not be transferred to any entity.

No international transfers of personal data have been foreseen.

Processing of “Employees” data

1. What kind of personal data do we process?

Identification data: name, ID card number, date of birth, address, phone number, email address, signature, image, social security number.

Personal characteristics data: gender, nationality, age, date and place of birth.

Social circumstances data: licenses and permits.

Economic and financial data: bank account, payroll data, tax deductions, other withholdings (if applicable).

Educational and professional data: profession, position, experience, qualifications.

2. What is the purpose of processing your personal data?

We process the personal data you provide us for the management of the employment relationship, payroll management, administrative and payment management, compliance with the fiscal and labor obligations of the company, access control, training and professional development management, and occupational risk prevention.

The provided personal data will be retained as long as the employment relationship is maintained. If after the employment relationship has ended, you decide to cancel your personal data, it will be kept until the legal deadlines defined by accounting, fiscal and labor regulations have expired, and once these periods have elapsed, your data will be deleted from our system.

3. What is the legitimacy for processing your data?

The legal basis for the processing of your data is the fulfillment of a labor contract, as well as compliance with a legal obligation of the controller.

4. Who will receive your data?

Our labor consultancy will process your data on our behalf solely for the purpose of managing the employment relationship and complying with legal obligations. It is possible that your data may be communicated to our labor consultancy as data processors.

Your data will be transferred to the entity we have contracted for occupational risk prevention, in particular for health surveillance, in accordance with the legal obligation established in the Occupational Risk Prevention Act.

Your personal data will not be transferred to any entity, except those that are necessary to public bodies by legal obligation.

International transfers of personal data have also not been planned.

Data Processing for “Job Applicants”

1. What type of personal data do we process?

Identifying data: name, ID card number, date of birth, phone number, email address, image.

Personal characteristics data: gender, nationality, age, date and place of birth.

Social circumstances data: hobbies.

Academic and professional data: profession, position, experience, qualifications.

2. What is the purpose of processing your personal data?

We process the personal data that you provide us for the management of the company’s selection processes.

The personal data provided will be kept until the interested party withdraws their consent to keep their curriculum vitae for future selection processes. If you decide to cancel your personal data, it will be deleted from our job applicant database. In any case, it will not be kept for more than 1 year.

3. What is the legitimacy for the processing of your data?

The legal basis for the processing of your data is the explicit consent requested from you.

4. Who will your data be communicated to?

Your personal data will not be transferred to any entity.

No international transfers of personal data have been planned.

Treatment of “Newsletter” Data

1. What type of personal data do we process?

Identifying information: email address

2. What is the purpose of processing your personal data?

We process personal data for sending commercial and advertising information to customers and potential customers.

Personal data will be kept until you object to processing by unsubscribing from the newsletter.

3. What is the legitimacy for the processing of your data?

The legal basis for processing your data is your express consent.

4. To which recipients will your data be communicated?

Your personal data will not be transferred to any entity, except those that are necessary to comply with legal obligations to the Security Forces and Corps.

It is possible that there are data processors, such as companies that we hire for sending the newsletter.

No international transfers of personal data are planned.

Data processing for “HANDY GYM APP”

1. What type of personal data do we process?

Identifying data: email, username, password, date of birth, gender, and nationality.

2. What is the purpose of processing your personal data?

We process personal data to provide customers of our product, HANDY GYM, with a series of instructions and usage guidelines for the tool.

Personal data will be kept until the user objects to the processing through unsubscribing from the APP.

3. What is the legal basis for processing your data?

The legal basis for processing your data is your express consent, which is given when you download the APP and register as a user.

4. To whom will your data be disclosed?

Your personal data will not be transferred to any entity, except those necessary to fulfill legal obligations to law enforcement agencies.

There may be data processing managers, such as companies that we contract to manage the APP.

No international transfers of personal data are foreseen either.

What are your rights when you provide us with your data?

In accordance with the applicable data protection regulations, you have a number of rights in relation to the processing of your personal data. The exercise of these rights will be free of charge for you, except in cases where manifestly unfounded or excessive requests are made, especially if they are repetitive.

These rights are as follows:

a. Right to information: You have the right to be informed in a concise, transparent, intelligible, and easily accessible manner, with clear and simple language, about the use and processing of your personal data.

b. Right of access: You have the right to request at any time that we confirm whether we are processing your personal data, to provide you with access to your personal data and information about its processing, and to obtain a copy of such data. The copy of your personal data that we provide to you will be free of charge, although requests for additional copies may be subject to a reasonable fee based on administrative costs. We may ask you to prove your identity or request further information that is necessary to manage your request.

c. Right of rectification: You have the right to request the rectification of inaccurate, outdated, or incomplete personal data concerning you. You may also request that incomplete personal data be completed, including by means of an additional statement.

d. Right of erasure: You have the right to request the erasure of your personal data when, among other reasons, the data is no longer necessary for the purposes for which it was collected. However, this right is not absolute, so our organization may continue to keep them duly blocked in the cases provided for by applicable regulations.

e. Right to restrict processing: You have the right to request that we restrict the processing of your personal data, which means that we may continue to store it but not continue to process it if any of the following conditions are met:

  • that you challenge the accuracy of the data, for a period that allows the controller to verify the accuracy of the data;
  • the processing is unlawful and you object to the deletion of the data and instead request that its use be limited;
  • our organization no longer needs the data for the purposes of processing, but you need it for the formulation, exercise or defence of claims;
  • you have objected to processing while it is being verified whether the legitimate grounds of our organization prevail over yours.

f. Right to data portability: You have the right to have your data transmitted to another data controller in a structured, commonly used, and machine-readable format. This right applies when the processing of your personal data is based on consent or the performance of a contract and such processing is carried out by automated means.

g. Right to object: This right allows you to object to the processing of your personal data, including profiling. We cannot comply with your right only when we process your data if we demonstrate legitimate grounds for the processing or for the formulation, exercise, or defence of claims.

h. Right not to be subject to automated decisions, including profiling: This right allows you not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly affects you. Unless such decision is necessary for the conclusion or performance of a contract, is authorized by law or is based on consent.

i. Right to withdraw consent: In cases where we have obtained your consent for the processing of your personal data for certain activities (for example, to send you commercial communications), you may withdraw it at any time. In this way, we will stop carrying out that specific activity for which you had previously consented, unless there is another reason that justifies the continuation of the processing of your data for these purposes, in which case we will notify you of such situation.

j. Right to file a complaint with a supervisory authority: You have the right to file a complaint with the Spanish Data Protection Agency, located at C/ Jorge Juan, 6, 28001 Madrid, 901 100 099 – 912 663 517 (www.agpd.es), or at the electronic address: https://sedeagpd.gob.es/sede-electronica- web/vistas/formQuejasSugerencias/seleccionarQuejaSugerencia.jsf

You may exercise the aforementioned rights by sending us a communication to the physical or electronic address indicated at the beginning of this document, accompanied by a document proving your identity and providing the necessary details to process your request.

Interested parties can obtain additional information about their rights on the website of the Spanish Data Protection Agency, www.agpd.es.

In accordance with article 23 of Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights (LOPDGDD), we inform you that you can restrict unwanted advertising by voluntarily and free of charge registering your data in an advertising exclusion file. Currently, there is only one file called Lista Robinson, which is managed by the Spanish Association of Digital Economy (ADIGITAL).

The Lista Robinson must be consulted by those who are going to carry out an advertising campaign in order to exclude registered individuals. However, even if you have registered in the Lista Robinson, merchants can send you advertising for their products or services if you are a customer or if you have given them your consent.

When registering in the Lista Robinson, you can choose the means or channel of communication through which you do not want to receive advertising (postal mail, telephone calls, email, or other means). Please note that registration in the Lista Robinson is effective from the third month from the date you register your data, so it is possible that during that period you may continue to receive some commercial communication.

You can consult the advertising exclusion systems on the website of the Spanish Data Protection Agency: https://www.aepd.es/areas/publicidad/index.html.

Finally, if you wish to register in the Lista Robinson, you can do so through this link: https://www.listarobinson.es/

This policy was last revised on March 21, 2023.

 

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