Last update: 07 February 2024
TURCO ESPAÑOLA, SA (hereinafter, “TURCO”) with NIF A-08128183 and address for these purposes at Calle Feixa Llarga, 19 Sector F (Z. Franca), 08040 – Barcelona (Barcelona), states that it is responsible for the processing of the data collected on the website www.turco-spain.com (hereinafter, the “Website”) in accordance with the obligations provided for in the Regulations (EU) 2016/679 General Data Protection (hereinafter, the “GDPR”), Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (hereinafter, the “LOPDGDD”) and Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (hereinafter, the “LSSICE”).
Completing all the data requested as mandatory through the Website is necessary in order to achieve optimal provision of the services made available to the User. If all the data required by TURCO is not provided, it is not guaranteed that the information and services provided can be provided, are provided correctly or adjusted to the needs of the User.
The term User/s is used here to refer to all persons of legal age who access the Website.
BASIC INFORMATION REGARDING DATA PROCESSING
| Data Controller | TURCO ESPAÑOLA, S.A. |
| Purpose of the processing | Provision of the service |
| Communications, queries and comments | |
| CV reception | |
| Legitimation of the processing | The processing of your data may be based on the execution of a contract and/or on your consent. |
|
Recipients |
No data will be transferred to third parties, except to our necessary collaborators. |
|
Rights |
Access, rectification, deletion, opposition, limitation of processing, data portability, unless subject to automated individual decisions, to revoke the consent given, as well as to file a claim with the Spanish Data Protection Agency, if deemed appropriate. |
| Additional information | You can consult detailed information on the protection of your data below. |
DETAILED INFORMATION ABOUT DATA PROCESSING
1. Identity and contact information of the Data Controller
In the terms of the applicable data protection regulations and, in particular, Regulation (EU) 2016/679, of the European Parliament and of the Council, of 27 April 2016, regarding the protection of natural persons regarding the processing of personal data and the free circulation of these data and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights, the Data Controller is:
| Data Controller | TURCO ESPAÑOLA, S.A. |
| Address | Calle Feixa Llarga, 19 Sector F (Z. Franca), 08040 – Barcelona (Barcelona) |
| Telephone | +34 93 335 03 58 |
| Contact E-mail | info@turco-spain.com |
2. Compliance with applicable regulations
TURCO has adapted the Website to the GDPR and the LOPDGDD. To this end, it has put into practice those policies, means and technical and organisational procedures to guarantee and protect the confidentiality, integrity and availability of your personal data.
The transmission of data by the user of TURCO services (hereinafter, the “User”) through the Website is carried out voluntarily and the user is informed prior to processing of the use and purposes thereof.
3. Principles we apply to your personal information
The data provided to TURCO by different means, online or offline contact forms or any other procedure used to collect your data, will be processed in accordance with current data protection regulations, and with the sole purpose of providing the service that has been reported to you.
When processing your personal data, we apply the following principles that comply with the requirements of the GDPR:
- Principle of legality, loyalty and transparency: We will always have a legal basis for the processing of your personal data for one or more specific purposes that we will inform you of in advance with absolute transparency. TURCO informs you that only the information necessary to achieve the purpose of the processing is collected and only the data that you have provided will be processed for the purpose(s) for which you were informed.
- Data minimisation principle: We will only request the data that is strictly necessary in relation to the reported purposes.
- Conservation period limitation principle: Personal data will be kept for the time strictly necessary until the purpose for which it was collected ends, and as long as the cause that legitimised the processing of the personal data is maintained. Once the cause that legitimised the processing has ended, the personal data will be kept duly blocked during the specification period of the actions that may arise from the relationship maintained between the parties and/or the conservation periods provided by law.
- Integrity principle: Your data will be processed in such a way that adequate security of personal data is guaranteed and confidentiality is guaranteed. You should know that we take all necessary precautions to prevent unauthorised access or misuse of data by third parties.
- Confidentiality principle: TURCO, in its capacity as Data Controller, guarantees confidentiality in the processing of all personal data of the User to which it has access. The Data Controller, like any other person involved in any phase of the processing, is subject to the strictest professional secrecy, with a special commitment to adopting the levels of protection and the necessary measures, both technical and organisational, to guarantee the security of personal data and prevent its alteration, misuse, loss, theft, unauthorised processing or access.
- Data accuracy principle: All information that the User provides to TURCO must be truthful, and the User will be solely responsible for any false or inaccurate statements made and any damages caused to TURCO or third parties.
TURCO reserves the right to exclude from the services any User who has provided false data, without prejudice to other legal actions that may apply.
4. Processing of personal data
4.1. Collection and processing of personal data
By providing us with their data through the Website or by any other means, the User guarantees that it is true, accurate, complete and updated, taking responsibility for any damage or loss, direct or indirect, that may be caused as a result of failure to comply with such obligation.
In the event that TURCO is provided with third party data, the User must have their consent and undertake to transfer the information contained in this Policy to them, exempting TURCO from any responsibility in this regard. However, TURCO may carry out verifications to verify this fact, adopting the appropriate due diligence measures, in accordance with data protection regulations.
4.2. Purpose of the processing
The purposes of the processing carried out by TURCO on the User’s personal data are:
| Processing of data | Purpose of the processing | Legal basis of the processing | Retention period |
| Provision of the service | Managing the contractual relationship with our clients, including sending communications related to the provision of the service, such as product news, among others. | Performance of a contract. | 6 years after the end of the contractual relationship, and where applicable, after exercising your right to object. |
| Communications, queries and comments | Properly attend to and manage the User’s queries, comments, incidents or suggestions made through the form and email provided on the Website. | Consent of the interested party. | 12 months after the consultations made or until the User revokes his or her consent. |
| CV reception | Managing the receipt of CVs and carrying out an evaluation of the CVs received for current and/or future job offers at TURCO. | Consent of the interested party. | 5 years after receipt of the CV. |
4.3. Category of data and interested parties
Taking into account the aforementioned purposes, TURCO collects and processes the following categories of User data:
- Identification data: name, surname, email address, address and telephone number.
- Occupation data: company to which they belong.
- Academic and professional data: candidates’ CVs.
The personal data collected belongs to the following category/s of interested parties: Users; Customers; Potential customers; Suppliers; Potential suppliers; and Candidates.
In relation to queries or requests made through the data collection forms available on the Website, the User is allowed to briefly explain the reason for the query or contact. Please note that TURCO will not respond to any personal queries, except those strictly established by current legislation. Under no circumstances will the User communicate data of special categories (for example: health data, religion, etc.) through the forms enabled on the Website. If they do so, the User shall exempt TURCO from all liability. In the event that inappropriate queries or content are sent, TURCO will proceed to eliminate them.
4.4. Automated individual decisions, including profiling
There is no provision for automated individual decision-making, including profiling.
5. Data processing by third parties and transfer
Depending on the purposes for which personal data is collected, your personal data may be processed by:
- Authorised personnel of TURCO or its representatives acting on its behalf, subject to the applicable data protection regulations in force.
- Administrations, Authorities and Public Bodies, including Courts and Tribunals, when required by applicable regulations.
- Third party external service providers that TURCO hires and who have the status of data processor [IT service providers that process information, data storage, maintenance of database support, software and applications]. All this is only after carrying out the necessary measures to ensure that we can share said information and after having signed a data processing contract with our data processors, in compliance with data protection regulations.
If there is a sale, merger, consolidation, change in corporate control, substantial transfer of assets, reorganisation or liquidation of TURCO then, at our discretion, we may transfer, sell or assign the information collected on the Website to one or more relevant parties.
6. Security measures
TURCO adopts the security levels required by the GDPR appropriate to the nature of the data that is processed at all times due to its activity. In this sense, it uses encryption techniques that do not allow a third party to track the identity of the User who interacts with our services. Likewise, it may also carry out secure anonymisation techniques for the personal data it processes to carry out its activity. However, technical security in a medium like the Internet is not impregnable and there may be malicious actions by third parties, although TURCO provides you with the means to avoid such actions.
7. International data transfers
We do not transfer the User’s personal data to third parties outside the European Union. In the event of international data transfers, all appropriate technical and organisational measures will be taken to guarantee the security of the data.
8. Rights of interested parties and their exercise
In accordance with the GDPR and the LOPDGDD, Users can exercise the following rights:
- Right of access: The User may ask TURCO if it is processing their data and, if so, access it.
- Right of rectification: The User may request rectification of the data if it is inaccurate or incomplete.
- Right to request the deletion of their data, when possible. In any case, at the time the User exercises this right, all personal data linked to their account, as well as the information and content included in their profile, will be deleted and will remain blocked until the end of the legal period provided.
- Right to request the limitation of processing: In this case we will only keep the data for the exercise or defence of claims.
- Right to object to processing: TURCO will stop processing personal data, with the exception that it must continue to be processed for reasons of compelling legitimate interest or for the exercise or defence of possible claims.
- Right to data portability: In the event that the User wants their data to be processed by another data controller, TURCO will facilitate the transfer of their data to the new controller if both have the necessary technical means to do so.
- Right not to be subject to a decision based solely on the automated processing of their personal data.
- Right to revoke consent: If the User has granted consent for a specific purpose, they may withdraw it whenever they wish, without affecting the legality of the processing based on the consent prior to its withdrawal.
- Right to file a claim with the Spanish Data Protection Agency: If you consider that a violation of data protection legislation has been committed regarding the processing of your personal data (aepd.es).
To exercise your rights, you can use the models and forms available on the official page of the Spanish Data Protection Agency (https://www.aepd.es/es/derechos-y-deberes/conoce-tus-derechos), and write to TURCO’s address or to the email address info@turco-spain.com, REF: “Data Protection”.
9. User Consent
The User states that they have read and expressly accepted this Privacy Policy, when the legal basis for the processing is their consent. They can withdraw consent at any time. The withdrawal of consent will not affect the legality of the processing prior to its withdrawal.
The User agrees to indemnify TURCO against any possible claims, fines or penalties that it may be forced to endure as a result of a breach by the User of the duty described in this paragraph.
10. Links to other websites
This Website contains links to other websites not managed by TURCO, so TURCO does not exercise any control over them, nor is it responsible for the information to which they have access. Please visit these websites directly to obtain information about their privacy policy, which provides information on the protection of your data, security, data collection and provisions regarding data transmission.
If you follow us on our social networks, review their privacy policies to obtain information on how they process and share your personal data, since TURCO does not exercise any control over them nor has any type of responsibility regarding the information to which these websites have access.
11. Changes to the privacy policy
We will only use personal data as established in the Privacy Policy that is in force at the time such data is collected.
TURCO reserves the right to modify this Privacy Policy at any time with effect from the date of publication of such modifications on the Website, so it is recommended to visit it each time it is accessed. In any case, if at any time we decide to process personal data differently from what was declared at the time it was obtained, the User will be informed of this, obtaining their consent if necessary.
In the event that any clause of this Privacy Policy is annulled or considered null, the rest of the conditions will not be affected, their validity and effect being fully preserved, in accordance with the regulations in force applicable at all times.
12. Applicable legislation
The privacy of all the information provided, both by the User through the different personal data request forms, and that accessible through the Website, is regulated by current data protection regulations, especially by the GDPR. and by the LOPDGDD.
13. Cookies
Access to the Website may involve the use of cookies. Cookies are small amounts of information that are stored in the browser used by each user so that the server remembers certain information that it can later use. This information allows you to be identified as a specific user and allows you to save your personal preferences, as well as technical information about the use and operation of the Website.
Those Users who do not wish to activate cookies or want to be informed before they are stored on their devices, can configure their own device for this purpose. For more information, you can consult our Cookies Policy.