TREATMENT MANAGER

Co-managers TUBOPLAST HISPANIA S.A., CTL – TH PACKAGING S.L., CTL-TH ENGINEERING, S.L.,

Postal address: C/Hermanos Lumiere 1, Parque Tecnológico de Álava, C.P. 01510 Miñano (Álava)

Email: lopd@ctlpack.com  Tel. 945 29 62 00

 

HOW DID WE OBTAIN YOUR DATA?

Obtaining of the interested party itself:  If you are already a customer, you have either facilitated them to us off or online on ordering our services in order to maintain the contractual relationship with you or, for example, if you have come to our offices or plant, you may have facilitated them to us when you accessed our facilities as a visitor. Similarly, your data may have been communicated to us by our sales network, following your providing of your data to any of our salespeople. The data categories we process are: identification data, postal or electronic mailing addresses, commercial information and financial data. We do not process specially protected data.

When you facilitate your personal data to us, you are guaranteeing that you are authorised to do so and that it is true, accurate and up-to-date, that it is not confidential and that it does not breach any contractual restriction or third-party rights and you commit yourself to refrain from impersonating other Users.

Automatically obtained on visiting our website: If you have provided us with the data through this website, you must be aware that we collect information, for example, when you access the site, when you register as a user, fill in any form with personal data or when you communicate with us directly by email.

When you visit our website data are sent from your browser to our server in order to optimise our services and improve your user experience, for example when you access the site or when you start using our Services through the services of third parties such as social networks or Google.  These data can be automatically gathered and stored by us or by third parties on our behalf. These data may include:

• the user’s IP address
• the time and date of the visit
• the URL of the site the user is coming from
• the pages visited on our website
• information about the browser used (browser type and version, operating system, etc.).

We may process and record these uses, sessions and related information either individually, with the help of third-party services or even by using cookies and other tracking technologies such as flash cookies and web analytics.

Our website has connectors to social networks, when you choose to interact with us through a social network, we cannot take responsibility for the privacy settings chosen by the user, the social network being able to report your IP address or which page you are visiting on our website and a cookie may be set to allow them to operate properly or for example when you name is included in the Likes that you give or in the comments you make in our page on the social network. If you do now want your personal data to be associated to these Likes or comments set your privacy settings to prevent it, giving a pseudonym to your data by, for example, setting yourself a nickname or alias that does not reveal your name and surname.

If you start the session on one of these social networks during your visit to our website, the social network can add this information to your profile and this information will be transferred to the social network. If you do not want this data transfer to be made, exit your social network session before you enter our websites or mobile apps, as it is not in our hands to influence this data collection and transfer through the social connectors.

If the user, through our official website on a social network, decides to publish and/or share texts, photos, videos and other kinds of information and/or contents, the former shall be the sole party responsible that such contents comply with the applicable legal framework. We remind you that you must respect the data of third parties, you must their privacy having special care in communicating or publishing their data of a personal nature. Only the rightful owner can authorise the processing of their personal data. The user may only publish on this page or on our official page on social networks, personal data, photographs and information or other content of which they are the owner and where the property belongs to them or with regards to which they have been granted the authorisation of third parties. If you facilitate or publish third party data, it is your responsibility to have their prior and express consent to use them, for communicating and publishing them it is your responsibility to inform them of the treatment of their data by us or their publication by you. The publication of third party data may infringe, in addition to the legislation on data protection, that relating to the right to honour, to intimacy or to the own image of the said third parties.

In any event, we may from both this website as well as from our pages on social networks, any content published by the user when we detect that the user has breached current legislation and that described in this privacy policy.

The Social Networks are no directly lodged in our Services. Your interactions with them are governed by their policies and not by ours. Read the privacy policies of these social networks for detailed information on the collection and transfer of personal data, your rights and on the settings of your privacy.

Communication by a third party of the data of the interested party: In the event where it is not the interested party concerned but a third party who provides us with the data on the former, your data may have been communicated, as applicable, by our sales or distributor network prior to the providing of your data to any of them.

 

THIRD PARTY DATA

You must respect the privacy of third parties, especially with respect to disclosure of their data of a personal nature. Please remember that as a user you can only provide and consent to processing of your own personal data and not those of third parties. If you provide us with third-person data you are assigning their information and it is your responsibility to obtain the prior and express consent of the third parties involved to use and provide said data. You are also responsible for informing them that their data has been added to our files.

The provision of third-party data without consent, in addition to infringing the data protection regulations, may also breach the right to honour, privacy and self-image of said third parties. These rights are protected under Organic Law 1/1982 5 of May on civil protection of the right to honour, personal and family privacy and one’s own image.

 

PURPOSE

We may process the data for different purposes, such as:

1. If you are a current or potential customer to maintain contact and communication with you, manage the contractual and/or sales relationship, including the after-sales and guarantee services.
2. If you are a mere user of our website or the sender or recipient of an email, to keep contact and communication with you and manage the online requests that you make to us.
3. If you submit curricular information or provide us with your CV, to contact you and manage the consequent selection processes that we may carry out.
4. In the event that you access our facilities as a visitor, to manage the access and control of visits.
5. To conduct opinion and/or satisfaction surveys and send you, by electronic communications, information about our activities, products and/or services similar to those requested (including advertising and/or sales communications for the effects of Article 21 of LSSICE 34/2002). If we already have a prior contractual relationship, we shall send such communications on the basis of our legitimate interest. In the event of not having a prior contractual relationship, we will only send you this kind of communications, if you authorise us for this by checking the option expressly included for the purpose on the related forms. The electronic communications that we send you, shall include in the communication itself, the option to stop receiving them. If you opt to do so, we shall cease to send you this kind of communications thereafter.

 

RETENTION PERIOD

We shall retain the personal information that you provide insofar as you do not request its deletion. Even after this has been requested, we shall keep them for the necessary time and limiting their processing, solely to complying with the legal/contractual obligations we are subject to and/or during the legal periods set for the expiry of any liability on our part and/or for the exercising or defence of claims derived from the relationship maintained with the interested party.

 

 

LEGITIMATION

The legal bases that legitimises us to process your data may be several:

On one hand there can be the legal relationship that unites us if you are a current customer/supplier or the pre-contractual relationship of any kind that may exist between the parties if you are a potential customer/supplier (for example, if you have requested information, an offer or a cost quote …).

This may also the case if you give your consent having made a request through our website, in the case of being a mere user or if you have sent us your curriculum or you have accessed our facilities as a visitor. This consent is unequivocally granted when you provide us with your data online or offline, it being deemed that such provision constitutes a clear assertive act that expresses said consent. You can withdraw this consent at any time by sending us an email to that effect to lopd@ctlpack.com but said withdrawal may involve that we cannot answer your request, take into account your curriculum or give you access to our facilities.

This may also be the case for compliance with the legislation for the prevention of money-laundering, tax matter or the penal code with regard to the establishment of a channel for complaints pursuant to article 31 bis of said code …

In accordance with recital 47 of the GDPR, it also constitutes a legal basis for processing your data in our legitimate interest as an organisation in order to:

• Keep in touch with you and inform you of our activities, products and/or services (including by means of electronic communications). If we already have a prior contractual relationship, we shall send such communications on the basis of our legitimate interest. Otherwise, we shall only send you this kind of communications, if you give us your consent by checking the option expressly included for the purpose on the related forms. In any event, the electronic communications that we send you, shall include in the communication itself, the option to stop receiving them thereafter.
• Conduct opinion and/or satisfaction surveys
• Communicate your data to other group companies in order to provide the customer with a comprehensive or specialised service that requires the intervention of interdisciplinary teams or for internal administrative purposes

 

RECIPIENTS

You are hereby informed that the data with which you have provided us may be disclosed the third-party organisations to comply with purposes directly related to the following legitimate assigner and assignee functions:

1. To the carriers responsible for the logistics of shipping and delivering our products.
2. To any of the companies that comprise the CTL- TH PACKAGING Group (currently, TUBOPLAST HISPANIA S.A., TAPSER S.A., CTL PACKAGING S.A.S., CTL-TH ENGINEERING, S.L.) for internal administrative purposes and for managing the contact and personnel selection processes carried out within the company group, in the event that you have provided us with your curriculum
3. To banking entities for management of accounts receivable or payable
4. To the organisations and bodies to which we are legally obliged to disclose information (the Tax Authorities, …)

 

International transfers

In the event that we use US suppliers who may have access to personal data, for the purpose of providing us with ancillary services to our business activity (accommodation, housing, software as a service, remote backup, computer support or maintenance services, email managers, the sending of emails and marketing emails, file transfers etc. …) these companies may differ or vary over time but in any event we will choose companies that adhere to the Privacy Shield agreement between the USA and the EU or that belong to countries that have been declared as having an adequate level of protection, which means that they oblige themselves to fulfil requirements equivalent to the Europeans ones in data protection matters. In any event, by the acceptance of this data protection policy you expressly and unequivocally authorise the communication of the data to said companies, thus being aware that this involves an international data transfer to a country not belonging to the European Economic Area and giving your unequivocal consent to said transfer.

 

RIGHTS

You may, when appropriate, exercise your rights of access, rectification, deletion, limitation and challenging their processing, as well as to not be the object of decisions based solely on the automated processing of your data, on the postal or email address indicated at the beginning of this privacy policy. In both cases by means of a written and signed request, attaching a copy of the National ID Document or passport or any other valid document to identify yourself. If you want to amend your data you must do so to the same address, the company hereby declining all responsibility in the event of not having done so.

Right of access: You can ask us what personal data we are processing and request us to send you a copy of them.

Right to rectification: You can request rectification of any inaccurate data of a personal nature or the completion of incomplete date, including by means of an additional declaration.

Right to suppression (right to be forgotten): You may request the suppression of your data of a personal nature when: they are no longer required for the purposes for which they were collected, you withdraw your consent, they have been improperly processed and for compliance with a legal obligation.

Right to restriction of processing: You may request the restriction of the processing of your data, in which case we will only store them for the exercising or defence of legal claims

Right to challenge: You may challenge the processing of your data if said processing is based on the legitimate interest of the file manager or it is for advertising purposes.

Once any of the above requests have been received we will respond to you within the legally established time limits. You may file a complaint to the Spanish Data Protection Agency. For information on your rights you can visit the website of the Spanish Data Protection Agency at www.aepd.es to obtain further information on the exercising of your rights and to request the forms required to do so.

 

DATA CATEGORY

The data categories we process are: identifying data; professional data; economic data, financial data; transactions of assets and of services.