Tower Consultores implement policies, procedures and guidelines to ensure that the security, integrity and confidentiality of the personal data in accordance with the provisions of regulation (EU) 2016/2017 of the European parliament and of the council of April 27th, 2016 with regard to the processing of personal data and the circulation of this data, as well as the Organic law 3/2018 of December 5th about protection of personal data and guarantee of digital rights.
Purposes to process your personal data
Personal data are processed by Tower as a part of administrative and commercial transactions with suppliers, customers, and employees.
The request for information and/or the contracting of the services of TOWER CONSULTORES. Before any transaction Tower previously will provide in any moment the terms and conditions. In case you do not provide us your data or give us incompletely will be impossible for us to provide the information requested or to carry out the transaction of our services
Manage the resume received through the form provides for this purpose on the website.
To manage the Internal claims Through the Compliance channel so that any person may reports acts of noncompliance with the internal and external regulations anonymously.
The processing of your data by TOWER CONSULTORES is carried out on the following legal bases that legitimize the process.
- Free, specific, informed, and unequivocal consent, insofar as we tell you by making this privacy policy available to you, which, after reading it, if you agree, you can accept using a declaration or an explicit affirmative action, such as ticking a box provided for this purpose.
- Necessary for the execution of a contract or to carry out steps at the request of the interested party before the conclusion of a contract.
- Compliance with a legal obligation to which TOWER CONSULTORES is subject, contained in Directive (EU) 2019/1937 of the European Parliament and of the Council of October 23rd, 2019, on the protection of persons who report breaches of Union law and in law 2/2023 of February 20th, regulating the protection of persons who report regulatory breaches and the fight against corruption.
- The processing is necessary for the performance of a mission carried out in the public interest or in the exercise of public powers vested in the controller: Control of risks of non-compliance within the Organization (Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights [Preamble V]; Art 30 of Law 2/2023 of February 20th, regulating the protection of persons who report regulatory infringements and the fight against corruption; Art. 9.2.g). RGPD).
Category of data processed.
The data collected by TOWER CONSULTORES is limited to the data necessary for the purposes described in this notice. These data may include, among others, the following: identification and contact data (surname, first name, professional and/or personal address, date of birth, telephone number, email address, and other contact data available to the interested parties, data relating to the monitoring of the business relationship, financial and economic situation, transactions and payments methods, payment of invoices, your opinions on TOWER CONSULTORES products and services, and data arising from the exercise of your rights.
Third-party recipients of personal data
TOWER CONSULTORES does not communicate the data to any third party unless legally required. However, these data may occasionally be transmitted to third parties for the purposes they were collected. Where the transmission of personal data to third parties is necessary for such purposes, TOWER CONSULTORES will ensure, in its capacity as data controller, that such third parties guarantee the same level of protection to the data concerned as is offered to them by TOWER CONSULTORES, and will require contractual guarantees so that, in particular, the data are processed exclusively for the purposes previously authorized, with all the confidentiality and security required.
Regarding the processing of personal data derived from the management of the internal complaints channel, we inform you that the personal data subject to processing will be communicated to CE CONSULTING NORTE, S.L. in its capacity as data processor with respect to the provision of the service related to the management of the channel. Likewise, personal data subject to processing may be communicated to the State Security Forces and Bodies, Jurisdictional Bodies and the Public Prosecutor’s Office for the purpose of reporting the commission of a possible crime (legal requirement).
International Transfers
TOWER CONSULTORES does not carry out international data transfers.
Automated individual decisions
TOWER CONSULTORES does not make decisions based solely on the automated processing of data and does not proceed to elaborate profiles based on the same.
Data retention period
The personal data provided will be kept for the time strictly necessary for the purposes indicated above and for the period for which legal liabilities may arise from the services offered.
ARSULIPO Rights
Any interested party has the right to confirm whether TOWER CONSULTORES is processing personal data concerning them.
By the provisions of the General Data Protection Regulation, we inform you that you may have, under certain conditions and without limitation, a right of access, opposition, and withdrawal of consent to the processing of personal data, in addition to the rights of limitation, rectification, portability, and deletion that can be exercised at any time by sending an email to: lgpd.tower@towerconsultores.com
Any claim will be answered in the shortest possible time and, in any case, within 30 days of receipt of your request. Considering the complexity and number of requests, this period may be extended by a further two months if necessary. The data controller will inform the data subject of the extension within one month of the request.
The data subject has the right to withdraw consent at any time without affecting the lawfulness of the processing based on the consent before its withdrawal.
To exercise these rights, the data subject may contact the following email address: lgpd.tower@towerconsultores.com
If you consider that your rights have not been duly addressed, you have the right to file a complaint with the competent authority, the Spanish Data Protection Agency www.aepd.es