Data protection Information Website
Contents
(B) Collection of Personal Data. 2
(C) Creation of Personal Data. 2
(D) Categories of Personal Data we may Process. 3
(E) Lawful basis for Processing Personal Data. 3
(F) Sensitive Personal Data. 4
(G) Purposes for which we may Process your Personal Data. 5
(H) Disclosure of Personal Data to third parties. 6
(I) International transfer of Personal Data. 6
(O) Cookies and similar technologies. 9
Privacy Policy
Summary: This notice explains how we may Process your Personal Data. This Notice may be amended or updated from time to time, so please check it regularly for updates.
This notice is issued by URSA Insulation, S.A on behalf of itself, its subsidiaries and its affiliates (together, “URSA”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our Sites, and other users of our products or services (together, “you”). Defined terms used in this Notice are explained in Section (S) below.
For the purposes of this Notice, URSA is the Controller. Contact details are provided in Section (R) below.
This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice.
(B) Collection of Personal Data
Summary: We may collect or obtain Personal Data about you: directly from you (e.g., where you contact us); in the course of our relationship with you (e.g., if you make a purchase); when you make your Personal Data public (e.g., if you make a public post about us on social media); when you visit our Sites; when you register to use any of our Sites, products, or services; or when you interact with any third party content or advertising on a Site. We may also receive Personal Data about you from third parties (e.g., law enforcement authorities).
Collection of Personal Data: We may collect Personal Data about you from the following sources:
- Data you provide: We may obtain your Personal Data when you provide it to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card).
- Relationship data: We may collect or obtain your Personal Data in the ordinary course of our relationship with you (e.g., if you purchase a product or service from us).
- Data you make public: We may collect or obtain your Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
- Site data: We may collect or obtain your Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.
- Registration details: We may collect or obtain your Personal Data when you use, or register to use, any of our Sites, products, or services.
- Content and advertising information: If you choose to interact with any third party content or advertising on a Site, we may receive Personal Data about you from the relevant third party.
- Third party information: We may collect or obtain your Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.)
Summary: We may also create Personal Data about you, such as records of your interactions with us, and details of your purchase history.
We may also create Personal Data about you, such as records of your interactions with us, and details of your purchase history.
(D) Categories of Personal Data we may Process
Summary: We may Process: your personal details (e.g., your name); demographic data (e.g., your age); your contact details (e.g., your address); records of your consents; purchase details; payment details (e.g., your billing address); information about our Sites (e.g., the type of device you are using); details of your employer (where relevant); information about your interactions with our content or advertising; and any views or opinions you provide to us.
We may Process the following categories of Personal Data about you:
- Personal details: given name(s); preferred name
- Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
- Contact details: correspondence address; address; telephone number; email address; and details of your public social media profile(s).
- Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
- Purchase details: records of purchases and prices; consignee name, address, contact telephone number and email address.
- Payment details: invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; and card expiry date; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques.
- Data relating to our Sites: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; username; password; security login details; usage data; aggregate statistical information.
- Employer details: where you interact with us in your capacity as an employee, the name, address, telephone number and email address of your employer, to the extent relevant.
- Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (including mouse hover, mouse clicks, any forms you complete (including incomplete forms not submitted) and any touchscreen interactions).
- Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.
(E) Lawful basis for Processing Personal Data
Summary: We may Process your Personal Data where: you have given your prior, express consent; the Processing is necessary for a contract between you and us; the Processing is required by applicable law; the Processing is necessary to protect the vital interests of any individual; or where we have a valid legitimate interest in the Processing.
In Processing your Personal Data in connection with the purposes set out in this Notice, we may rely on one or more of the following legal bases, depending on the circumstances:
- Consent: We may Process your Personal Data where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);
- Contractual necessity: We may Process your Personal Data where the Processing is necessary in connection with any contract that you may enter into with us;
- Compliance with applicable law: We may Process your Personal Data where the Processing is required by applicable law;
- Vital interests: We may Process your Personal Data where the Processing is necessary to protect the vital interests of any individual; or
- Legitimate interests: We may Process your Personal Data where we have a legitimate interest in carrying out the Processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.
Summary: We do not seek to collect or otherwise Process your Sensitive Personal Data. Where we need to Process your Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.
We do not seek to collect or otherwise Process your Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:
- Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
- Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);
- Establishment, exercise or defence of legal rights: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal rights; or
- Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
(G) Purposes for which we may Process your Personal Data
Summary: We may Process your Personal Data for the following purposes: providing products and services to you; operating our Sites; communicating with you; managing our IT systems; health and safety; financial management; conducting surveys; ensuring the security of our premises and systems; conducting investigations where necessary; compliance with applicable law; and improving our Sites, products and services.
We may process your personal data for the following purposes, subject to applicable law:
- Provision of products and services to you: providing our Sites, products, or services to you; providing you with products and services that you have requested; providing you with promotional items at your request; and communicating with you in relation to those products and services.
- Our Sites: operating and managing our Sites; providing content to you; displaying advertising and other information to you; communicating and interacting with you via our Sites; and notifying you of changes to any of our Sites, our products, or our services.
- Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required.
- Communications and IT operations: management of our communications systems; operation of IT security systems; and IT security audits.
- Health and safety: health and safety assessments and record keeping; and compliance with related legal obligations.
- Financial management: sales; finance; corporate audit; and vendor management.
- Surveys: engaging with you for the purposes of obtaining your views on our products and services.
- Security: physical security of our premises (including records of visits to our premises; and CCTV recordings); and electronic security (including login records and access details).
- Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
- Legal proceedings: establishing, exercising and defending legal rights.
- Legal compliance: compliance with our legal and regulatory obligations under applicable law.
- Improving our Sites, products and services: identifying issues with our Sites, our products, or our services; planning improvements to our Sites, our products, or our services; and creating new Sites, products, or services.
(H) Disclosure of Personal Data to third parties
Summary: We may disclose your Personal Data to: legal and regulatory authorities; our external advisors; our Processors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third party providers of advertising, plugins or content used on our Sites.
We may disclose your Personal Data to other entities within the Etex group, for legitimate business purposes (including operating our Sites, and providing products and services to you), in accordance with applicable law. In addition, we may disclose your Personal Data to:
- legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
- accountants, auditors, lawyers and other outside professional advisors to Etex, subject to binding contractual obligations of confidentiality;
- third party Processors (such as payment services providers; shipping companies; etc.), located anywhere in the world, subject to the requirements noted below in this Section (H);
- any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;
- any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;
- any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
- any relevant third party provider, where our Sites use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.
If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.
(I) International transfer of Personal Data
Summary: We may transfer your Personal Data to recipients in other countries. Where we transfer Personal Data from the EEA or UK to a recipient outside the EEA or UK that is not in an Adequate Jurisdiction, we do so on the basis of Standard Contractual Clauses.
Because of the international nature of our business, we may need to transfer your Personal Data within the Etex group, and to third parties as noted in Section (H) above, in connection with the purposes set out in this Notice. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
Where we transfer your Personal Data from the EEA or UK to recipients located outside the EEA or UK who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses. You may request a copy of our [Standard Contractual Clauses] using the contact details provided in Section (R) below.
Please note that when you transfer any Personal Data directly to an Etex entity established outside the EEA or UK, we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Privacy Policy.
Summary: We implement appropriate technical and organisational security measures protect your Personal Data. Please ensure that any Personal Data that you send to us are sent securely.
We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.
Summary: We take every reasonable step to ensure that your Personal Data are kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.
We take every reasonable step to ensure that:
- your Personal Data that we Process are accurate and, where necessary, kept up to date; and
- any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay. From time to time we may ask you to confirm the accuracy of your Personal Data.
Summary: We take every reasonable step to limit the volume of your Personal Data that we Process to what is necessary.
We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice.
Summary: We take every reasonable step to ensure that your Personal Data are only retained for as long as they are needed. We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice.
The criteria for determining the duration for which we will keep your Personal Data are as follows:
- we will retain copies of your Personal Data in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Notice, unless applicable law requires a longer retention period. In particular, we may retain your Personal Data for the duration of any period necessary to establish, exercise or defend any legal rights.
Summary: Under applicable law, you may have a number of rights, including: the right not to provide your Personal Data to us; the right of access to your Personal Data; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Data; the right to object to the Processing of your Personal Data; the right to have your Personal Data transferred to another Controller; the right to withdraw consent; and the right to lodge complaints with Data Protection Authorities. We may require proof of your identity before we can give effect to these rights.
Subject to applicable law, you may have a number of rights regarding the Processing of your Relevant Personal Data, including:
- the right not to provide your Personal Data to us (however, please note that we may be unable to provide you with the full benefit of our Sites, our products, or our services, if you do not provide us with your Personal Data – e.g., we may not be able to process your orders without the necessary details);
- the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
- the right to request rectification of any inaccuracies in your Relevant Personal Data;
- the right to request, on legitimate grounds:
- erasure of your Relevant Personal Data; or
- restriction of Processing of your Relevant Personal Data;
- the right to object, on legitimate grounds, to the Processing of your Relevant Personal Data by us or on our behalf;
- the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
- where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
- the right to lodge complaints with a Data Protection Authority regarding the Processing of your Relevant Personal Data by us or on our behalf.
This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (R) below. Please note that:
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- we may require proof of your identity before we can give effect to these rights; and
- where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.
(O) Cookies and similar technologies
Summary: We may Process your Personal Data by placing or reading Cookies and similar technologies. For more information, please see our Cookie Policy [link to be inserted].
When you visit a Site we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Data through Cookies and similar technologies, in accordance with our Cookie Policy.
Summary: Our Terms & Conditions govern all use of our sites. All use of our Sites, our products, or our services is subject to our Terms & Conditions. We recommend that you review our Terms of Use regularly, in order to review any changes, we might make from time to time.
Summary: We may Process your Personal Data to contact you with information regarding products or services that may be of interest to you. You may unsubscribe for free at any time. We may Process your Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding products or services that may be of interest to you. If we provide products or services to you, we may send information to you regarding our products or services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.
You may unsubscribe from our promotional email list at any time by:
- simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any products or services you have requested.
- Or You may update your contact preferences at any time by visiting our Contact preference
Summary: You may contact us by post, telephone, email, or using our online contact form. If you have any comments, questions or concerns about any of the information in this Notice, or any other issues relating to the Processing of Personal Data carried out by us, or on our behalf, please contact:
The Privacy Officer
Etex Building Performance Limited c/o Etex SA/NV
PassPort Building
Luchthaven Brussel Nationaal, Gebouw 1K
1930 Zaventem
Belgium
- “Adequate Jurisdiction” a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.
- “Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Notice, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
- “Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
- “Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
- “EEA” means the European Economic Area.
- “Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
- “Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- “Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
- “Relevant Personal Data” means Personal Data in respect of which we are the Controller. It expressly does not include Personal Data of which we are not the Controller.
- “Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.
- “Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
- “Site” means any website operated, or maintained, by us or on our behalf.
Data protection information to our customers
We are committed to protect your personal data and comply with applicable data protection law, in particular the EU General Data Protection Directive («GDPR») and, and we only process your personal data on the basis of a statutory provision or if the data subject has declared consent.
In this data protection information, we explain which information (including personal data) are processed by us in connection with the business relationship between you and us.
- Who is responsible for the processing of personal data?
The controller responsible for the processing of personal data is URSA INSULATION, SA, Paseo de Recoletos, 3, 28004 Madrid. Any reference to «we» or «us» in this data protection information is a reference to the aforementioned entity.
Our data protection coordinator may be contacted via the aforementioned means or via privacy.ursa@etexgroup.com.
- Which data do we process?
The performance of our business relationships requires the processing of data related to our customers. If this data concern a natural person (e.g. if you are a single trader and enter into a business relationship with us), it is considered as personal data. Regardless of the legal form of our contract partners, we process data concerning the contact persons acting for a customer.
Please make this data protection information available to the persons within your organization that are involved in the business relationship with us («contact persons«)
- Basic data:We process certain general data concerning our customers and the contact persons as well as the business relationship with us, collectively «basic data». Basic data include a) any information provided to us in the course of establishing a business relationship or requested by us from our customers or a contact person (e.g., name, address and other contact details; and b) any information collected and processed by us in connection with the establishment of the business relationship (e.g., the details of the agreements entered into)
- Performance data:We process personal data collected in the course of the business relationship other than by merely updating basic data and that we refer to as «performance data». Performance data include: a)Information on the performance of contractual obligations by our customers on the basis of the agreements entered into; b) Information on the performance of contractual obligations by us on the basis of the agreements entered into; c) Information provided by a customer or a contact person in the course of our business relationship, be it actively or upon our request; and d) personal data that are provided to us in the course of our business relationship by our customer, a contact person or by third parties;
- To the extent permitted by law, we can add personal data provided by third parties to the aforementioned basic and performance data. Such data may include information regarding the commercial standing / rating of our customers if necessary for the assessment of financial risks (e.g. late payments).a) Information on the performance of contractual obligations by our customers on the basis of the agreements entered into.
III. For which purposes and on which legal basis do we process your personal data?
- We process basic, performance and usage data for the performance of the contractual relationships with our customers or for pre-contractual measures on the basis of Article 6 para 1 b) GDPR. Regardless of the legal form of our customers, we process basic and performance data concerning one or more contact persons for the purpose of our justified interest in the performance of the business relationship on the basis of Article 6 para 1 f) GDPR.
- We may process basic, performance and usage data also for compliance with legal obligations to which we are subject; this processing is based on Article 6 para 1 c) GDPR. Legal obligations may in particular include the mandatory disclosure of personal data to (tax) authorities. To extent necessary, we process personal data (in addition to the processing for the purposes of the business relationship or to comply with legal obligations) for the purposes of our justified interests or the justified interests of a third party on the basis of Article 6 para 1 f) GDPR.
Justified interest may include:- group-wide processes for internal administration of customer data
- the establishment of or defence against legal claims
- the prevention and investigation of criminal offences
- maintenance of security for our information technology systems
- the maintenance of security of our premises and infrastructure
- management and further development of our business operations including risk management
If we provide to a natural person the option to declare a consent in the processing of personal data, we process the personal data covered by the consent for the purposes specified in such consent on the basis of Article 6 para 1 a) GDPR.
- Please note that the declaration of consent is voluntarily, that failure to declare consent or the withdrawal of a consent may, nevertheless, have consequences, and we will inform about such consequences before you are given the option to declare your consent consent may be withdrawn at any time with effect for the future, e.g. by providing notice to us via mail, fax, email using the contact information specified on the first page of this data protection notice.
- Is there an obligation to provide personal data?
The provision of the basic and performance data specified in section II above is necessary for entering into and maintaining a business relationship with us, unless specified otherwise before or at collection of the data. Without the provision of these data, were are not able to enter into and maintain a business relationship.
If we collect additional data, we will indicate if the provision of such information is based on a legal or contractual obligation or necessary for the performance of an agreement. We usually indicate which information may be provided voluntarily and is neither based on a legal or contractual obligation nor necessary for the purposes of an agreement.
- Who has access to personal data?
Personal data are generally processed within our company. Depending on the categories of personal data, only dedicated departments / organizational units are granted access to your personal data. Such units include in particular the Sale department and – if data are processed via our IT infrastructure – also our IT department. Based on a role / rights management concept, access to personal data is limited to the functions and the extent necessary for the respective purpose of the processing.
If and to the extent permitted by law, we may transfer your personal data to recipients outside of our company. Such external recipients may include affiliated companies within Etex group.
Service providers that – on the basis of separate agreements with us – provide certain services possibly including the processing of personal data, as well as approved subcontractors of our service providers; private or public bodies, to the extent we are obliged to transfer your personal data on the basis of a legal obligation to which we are subject.
- Do we use automated decision-making?
In the course of the business relationship we generally do not use automated decision-making (including profiling) within the meaning of Article 22 GDPR. If we apply such processes in the future, we will inform data subjects separately in accordance with the applicable statutory provisions.
VII. Are data transferred to countries outside the EU / the EEA?
Personal Information that we collect may be transferred to, and stored at, any of Etex’s affiliates and service providers in countries outside the EEA which do not necessarily offer an adequate level of protection of your Personal Data.
We comply with applicable legal requirements for the above transfer of your Personal Information, including the implementation of appropriate safeguards to ensure its protection. This implies reliance on specific derogations and safeguards set out in the GDPR, including the relevant standard contractual clauses.
VIII. How long are your data stored?
We generally store personal data as long as we have a justified interest in the retention of such data and there the interest of the data subject in refraining from the further processing do not prevail.
Even without a justified interest, we may continue to store the data if there is a legal obligation (e.g. to comply with statutory retention obligations). We delete personal data even without an action by the data subject as soon as further retention is no longer necessary for the purposes for which the data were collected or otherwise processed or if further retention is not permitted by law otherwise.
In general, basic data and the additional data collected in the course of the business relationship at least until the end of the respective business relationship. The data are deleted in any case if the purposes for the collection or processing were achieved. This point in time may be after the end of the business relationship with us. If personal data need to be stored to comply with a legal obligation, such data is retained until the end of the respective retention period. If personal data are only processed to comply with a statutory retention obligation, the access to such data is usually restricted so that the data are only accessible if needed for the purpose of the retention obligation.
- What are the rights of a data subjects?
A data subject may
- request access to his/her personal data, Article 15 GDPR
- request the rectification of incorrect personal data, Article 16 GDPR
- request the erasure of his/her personal data, Article 17 GDPR
- request the restriction of the processing of his/her personal data, Article 18 GDPR
- exercise the right to data portability, Article 20 GDPR
- object the processing of his/her personal data, Article 21 DSGVO
The aforementioned rights may be asserted against us, e.g. by providing notice to us via the contact details specified on the first page of this data protection information.
In case of further questions, you may also get in touch with our data protection coordinator.
In addition, the data subject is entitled to lodge a complaint regarding the handling of personal data with the competent supervisory authority, Article 77 GDPR.
Data protection information to our suppliers
We are committed to protect your personal data and comply with applicable data protection law, in particular the EU General Data Protection Directive («GDPR«) and, and we only process your personal data on the basis of a statutory provision or if the data subject has declared consent.
In this data protection information, we explain which information (including personal data) are processed by us in connection with the business relationship between you and us.
- Who is responsible for the processing of personal data?
The controller responsible for the processing of personal data is URSA INSULATION, SA, Paseo de Recoletos, 3, 28004 Madrid. Any reference to «we» or «us» in this data protection information is a reference to the aforementioned entity.
Our data protection coordinator may be contacted via the aforementioned means or via privacy.ursa@etexgroup.com.
- Which data do we process?
The performance of our business relationships requires the processing of data related to our customers. If this data concern a natural person (e.g. if you are a single trader and enter into a business relationship with us), it is considered as personal data. Regardless of the legal form of our contract partners, we process data concerning the contact persons acting for a customer.
Please make this data protection information available to the persons within your organization that are involved in the business relationship with us («contact persons«).
- Basic data:We process certain general data concerning our customers and the contact persons as well as the business relationship with us, collectively «basic data».
Basic data include:- any information provided to us in the course of establishing a business relationship or requested by us from our customers or a contact person (e.g., name, address and other contact details; and
- any information collected and processed by us in connection with the establishment of the business relationship (e.g., the details of the agreements entered into)
- Performance data:We process personal data collected in the course of the business relationship other than by merely updating basic data and that we refer to as «performance data».
Performance data include:- Information on the performance of contractual obligations by our customers on the basis of the agreements entered into
- Information on the performance of contractual obligations by us on the basis of the agreements entered into
- Information provided by a customer or a contact person in the course of our business relationship, be it actively or upon our request; and
- personal data that are provided to us in the course of our business relationship by our customer, a contact person or by third parties
- To the extent permitted by law, we can add personal data provided by third parties to the aforementioned basic and performance data. Such data may include information regarding the commercial standing / rating of our customers if necessary for the assessment of financial risks (e.g. late payments). a) Information on the performance of contractual obligations by our customers on the basis of the agreements entered into.
III. For which purposes and on which legal basis do we process your personal data?
- We process basic, performance and usage data for the performance of the contractual relationships with our customers or for pre-contractual measures on the basis of Article 6 para 1 b) GDPR. Regardless of the legal form of our customers, we process basic and performance data concerning one or more contact persons for the purpose of our justified interest in the performance of the business relationship on the basis of Article 6 para 1 f) GDPR.
- We may process basic, performance and usage data also for compliance with legal obligations to which we are subject; this processing is based on Article 6 para 1 c) GDPR. Legal obligations may in particular include the mandatory disclosure of personal data to (tax) authorities.
- To extent necessary, we process personal data (in addition to the processing for the purposes of the business relationship or to comply with legal obligations) for the purposes of our justified interests or the justified interests of a third party on the basis of Article 6 para 1 f) GDPR.
Justified interest may include:- group-wide processes for internal administration of customer data
- the establishment of or defence against legal claims
- the prevention and investigation of criminal offences
- maintenance of security for our information technology systems
- the maintenance of security of our premises and infrastructure
- management and further development of our business operations including risk management
- If we provide to a natural person the option to declare a consent in the processing of personal data, we process the personal data covered by the consent for the purposes specified in such consent on the basis of Article 6 para 1 a) GDPR.
Please note that the declaration of consent is voluntarily, that failure to declare consent or the withdrawal of a consent may, nevertheless, have consequences, and we will inform about such consequences before you are given the option to declare your consent consent may be withdrawn at any time with effect for the future, e.g. by providing notice to us via mail, fax, email using the contact information specified on the first page of this data protection notice. - Is there an obligation to provide personal data?
The provision of the basic and performance data specified in section II above is necessary for entering into and maintaining a business relationship with us, unless specified otherwise before or at collection of the data. Without the provision of these data, were are not able to enter into and maintain a business relationship.
If we collect additional data, we will indicate if the provision of such information is based on a legal or contractual obligation or necessary for the performance of an agreement. We usually indicate which information may be provided voluntarily and is neither based on a legal or contractual obligation nor necessary for the purposes of an agreement.
- Who has access to personal data?
Personal data are generally processed within our company. Depending on the categories of personal data, only dedicated departments / organizational units are granted access to your personal data. Such units include in particular the Sale department and – if data are processed via our IT infrastructure – also our IT department. Based on a role / rights management concept, access to personal data is limited to the functions and the extent necessary for the respective purpose of the processing.
If and to the extent permitted by law, we may transfer your personal data to recipients outside of our company. Such external recipients may include affiliated companies within Etex group.
service providers that – on the basis of separate agreements with us – provide certain services possibly including the processing of personal data, as well as approved subcontractors of our service providers; private or public bodies, to the extent we are obliged to transfer your personal data on the basis of a legal obligation to which we are subject.
- Do we use automated decision-making?
In the course of the business relationship we generally do not use automated decision-making (including profiling) within the meaning of Article 22 GDPR. If we apply such processes in the future, we will inform data subjects separately in accordance with the applicable statutory provisions.
VII. Are data transferred to countries outside the EU / the EEA?
Personal Information that we collect may be transferred to, and stored at, any of Etex’s affiliates and service providers in countries outside the EEA which do not necessarily offer an adequate level of protection of your Personal Data.
We comply with applicable legal requirements for the above transfer of your Personal Information, including the implementation of appropriate safeguards to ensure its protection. This implies reliance on specific derogations and safeguards set out in the GDPR, including the relevant standard contractual clauses.
VIII. How long are your data stored?
We generally store personal data as long as we have a justified interest in the retention of such data and there the interest of the data subject in refraining from the further processing do not prevail.
Even without a justified interest, we may continue to store the data if there is a legal obligation (e.g. to comply with statutory retention obligations). We delete personal data even without an action by the data subject as soon as further retention is no longer necessary for the purposes for which the data were collected or otherwise processed or if further retention is not permitted by law otherwise.
In general, basic data and the additional data collected in the course of the business relationship at least until the end of the respective business relationship. The data are deleted in any case if the purposes for the collection or processing were achieved. This point in time may be after the end of the business relationship with us. If personal data need to be stored to comply with a legal obligation, such data is retained until the end of the respective retention period. If personal data are only processed to comply with a statutory retention obligation, the access to such data is usually restricted so that the data are only accessible if needed for the purpose of the retention obligation.
- What are the rights of a data subjects?
A data subject may
- request access to his/her personal data, Article 15 GDPR
- request the rectification of incorrect personal data, Article 16 GDPR
- request the erasure of his/her personal data, Article 17 GDPR
- request the restriction of the processing of his/her personal data, Article 18 GDPR;
exercise the right to data portability, Article 20 GDPR - object the processing of his/her personal data, Article 21 DSGVO.
The aforementioned rights may be asserted against us, e.g. by providing notice to us via the contact details specified on the first page of this data protection information.
In case of further questions, you may also get in touch with our data protection coordinator.
In addition, the data subject is entitled to lodge a complaint regarding the handling of personal data with the competent supervisory authority, Article 77 GDPR.
Data protection information to our employees
Processing of employee data
We are committed to protect your personal data and comply with applicable data protection law, in particular the EU General Data Protection Regulation («GDPR») and we only process your personal data on the basis of a statutory provision, your employment contract, or our legitimate interests, or if you have declared your consent.
In this data protection notice, we explain which information (including personal data) are processed by us in connection with your employment relationship.
- Who is responsible for the processing of personal data?
The controller responsible for the processing of your personal data is URSA Insulation, S.A., Paseo de Recoletos, 3, 28004 Madrid, Spain, as your employer. Therefore, any reference to «we» or «us» in this data protection information is a reference to the aforementioned entity.
Our data protection coordinator may be contacted via the aforementioned means or via privacy.ursa@etexgroup.com.
- Which data do we process?
The performance of your employment relationship requires the processing of personal data:
- Basic data:We process certain general data in relation to your person and your employment relationship with us, collectively «basic data».
Basic data include:- any information provided by you in the course of the recruitment process or that we requested from you (e.g., gender treatment, name, surname, address, telephone number, email address, date of birth, marital status, nationality, national identity card/ passport number, tax identification number, social security number, and information on your education and previous employment; and
- any information stored in connection with our hiring decision (in particular the details of your employment agreement and information on your position and seniority within our organization).
- Performance data:We process personal data collected in the course of your employment other than by merely updating your basic data and that we refer to as «performance data».
Performance data include:- Information on the performance of your employee tasks, such as your work / absence times, skills, and the assessment of your performance, if applicable
- Information on our performance of the employment relationship, such as our payments to you or other benefits or compensation, banking data, contribution bases, or taxes or contributions paid or payable on your behalf
- Personal data provided to us in the course of your employment, either by you actively or upon our request, or by third parties (in particular public bodies such as social insurance bodies or (tax) authorities). This may include information on sick leave, pregnancy, the birth of a child, maternity leave, disabilities, a marriage or comparable changes of marital status.
- Usage data:We process personal data collected in the course of your employment due to your use of our company infrastructure.
Usage data include:- Information regarding your use of our information technology infrastructure (such as your business email account, internet access, landline and mobile services –data and voice-, or other applications, programs or devices provided to you); and
- Information on your use of other company infrastructure such as infrastructure collecting user data when accessed by an employee, like connected machines or time management applications.
- The aforementioned categories of data may include special categories of personal data in the sense of Article 9.1 GDPR, in particular
- Health data (e.g., the information on your inability to work due to illness, or whenever there is a claim under the insurance policies contracted to insure the employees
- Trade union membership data (only whenever this information is provided by you); and
- Biometric data –photographs- (only whenever they are provided by you).
III. For which purposes and on which legal basis do we process your personal data?
- We process basic, performance and usage data for the performance of your employment relationship with us on the basis of Article 6.1(b) GDPR.
- We may process basic, performance and usage data also for compliance with legal obligations to which we are subject; this processing is based on Article 6.1(c) GDPR. Legal obligations may in particular include the mandatory disclosure of personal data to social insurance bodies and (tax) authorities, together with general retention mandatory provisions.
- To the extent necessary, we process personal data (in addition to the processing for the purposes of the employment relationship or to comply with legal obligations) for the purposes of our justified interests or the justified interests of a third party on the basis of Article 6.1(f) GDPR.
Justified interest may include:- group-wide processes for internal administration of employee data
- the establishment of or defence against legal claims
- the prevention and investigation of criminal offences
- maintenance of security for our information technology systems
- the maintenance of security of our premises and infrastructure
- management and further development of our business operations including risk management
- costs and headcount control within the Human Resources Department
- filling of vacancies, promotion of employees or management of geographical and functional mobility
- to obtain subsidies and subsidized financing of the available Public Aid Lines; and
- recruitment and career development processes.
- If the categories of data specified in section II above contain special categories of personal data (e.g. health data, trade union membership, biometric data), we process these data either for carrying out the obligations in the field of employment and social security and social protection law on the basis of Article 9.2(b) GDPR; on the basis of your making the data manifestly public according to Article 9.2.(e) GDPR; or for the establishment, exercise or defense of legal claims on the basis of Article 9.2(f) GDPR.
- If we provide – during the recruitment process or in the course of the employment – the option to declare a consent in the processing of personal data, we process the personal data covered by your consent for the purposes specified in such consent on the basis of Article 6.1(a) GDPR. If the consent refers to special categories of personal data (such as health data), the processing is based on Article 9.2(a) GDPR.
Please note that the declaration of your consent is always voluntarily, and neither the declaration of consent nor a later withdrawal of consent has negative consequences for the performance of your employment relationship; that failure to declare consent or the withdrawal of a consent may, nevertheless, have consequences, and we will inform you about such consequences before you are given the option to declare your consent; you may withdraw your consent at any time with effect for the future, e.g. by providing notice to us via mail, email using the contact information specified on the first page of this data protection notice. - Are you obliged to provide data?
The provision of the basic, performance and usage data specified in section II above is necessary for entering into and maintaining an employment relationship with us, unless specified otherwise before or at collection of the data. Without the provision of these data, were are not able to enter into and maintain an employment relationship with you.
If we collect additional data from you, we will inform you if the provision of such information is based on a legal or contractual obligation or necessary for the performance of an agreement (in particular your employment agreement). We usually indicate which information may be provided voluntarily and is neither based on a legal or contractual obligation nor necessary for the purposes of an agreement.
- Who obtains or has access to your data?
Your personal data are generally processed within our company. Depending on the categories of personal data, only dedicated departments / organizational units are granted access to your personal data. Such units include in particular the HR department, your managers, the Legal department in case of establishment of or defence against legal claims, and – if data are processed via our IT infrastructure – also our IT department. Based on a role / rights management concept, access to personal data is limited to the functions and the extent necessary for the respective purpose of the processing.
If and to the extent permitted by law, we may transfer your personal data to recipients outside of our company. Such external recipients may include affiliated companies within Etex group, to which we may transfer personal data for internal administration of employee data; service providers that – on the basis of separate agreements with us – provide certain services possibly including the processing of personal data, as well as approved subcontractors of our service providers; private or public bodies, to the extent we are obliged to transfer your personal data on the basis of a legal obligation to which we are subject; and business partners, to the extent the transfer of personal data (e.g. your business contact details) is necessary for the performance of your employment relationshwip with us.
- Do we use automated decision-making?
In the course of the recruitment process and the employment relationship we do not use automated decision-making (including profiling) within the meaning of Article 22 GDPR. If we apply such processes in the future, we will inform you separately in accordance with the applicable statutory provisions.
VII. Are data transferred to countries outside the EU / the EEA?
Personal Information that we collect may be transferred to, and stored at, any of Etex’s affiliates and service providers in countries outside the EEA which do not necessarily offer an adequate level of protection of your Personal Data.
We comply with applicable legal requirements for the above transfer of your Personal Information, including the implementation of appropriate safeguards to ensure its protection. This implies reliance on specific derogations and safeguards set out in the GDPR, including the relevant standard contractual clauses.
VIII. How long are your data stored?
We generally store your personal data as long as we have a justified interest in the retention of such data and there your interests in refraining from the further processing do not prevail.
Even without a justified interest, we may continue to store the data if there is a legal obligation (e.g. to comply with statutory retention obligations). We delete your personal data even without an action from your side as soon as further retention is no longer necessary for the purposes for which the data were collected or otherwise processed or if further retention is not permitted by law otherwise.
In general, your basic data and the additional data collected in the course of your employment are retained at least until the end of your employment. The data are deleted in any case if the purposes for the collection or processing were achieved. This point in time may be after the end of your employment relationship with us. If personal data need to be stored to comply with a legal obligation, such data is retained until the end of the respective retention period. If personal data are only processed to comply with a statutory retention obligation, the access to such data is usually restricted so that the data are only accessible if needed for the purpose of the retention obligation.
- What are your rights as a data subject?
As a data subject, you may
- request access to your personal data, Article 15 GDPR
- request the rectification of incorrect personal data, Article 16 GDPR
- request the erasure of your personal data, Article 17 GDPR
- request the restriction of the processing of your personal data, Article 18 GDPR
- exercise your right to data portability, Article 20 GDPR
- object the processing of your personal data, Article 21 DSGVO.
The aforementioned rights may be asserted against us, e.g. by providing notice to us via the contact details specified on the first page of this data protection notice.
In case of further questions, you may also get in touch with our data protection coordinator.
In addition, you are entitled to lodge a complaint regarding the handling of your personal data with the competent supervisory authority, Article 77 GDPR.
Data protection information to our business partners
Processing of business partner data
We are committed to protect your personal data and comply with applicable data protection law, in particular the EU General Data Protection Directive («GDPR»), and we only process your personal data on the basis of a statutory provision or if the data subject has declared consent.
In this data protection information we inform you which information we process from our business partners. For the purpose of this data protection information business partners are to be those companies, function of persons, with which we do not have a contractual relationship regarding the delivery of our goods or the rendering of services, but with which we conduct nevertheless business contacts and relationships. These business contacts may be used for providing information about goods and services in single cases or also regularly. Business partners are for us i.e. official or private house builder, project developer, investors, architects, construction engineers, craftsmen and authorizes experts, who are involved in building projects or other projects, for which our products and services may be relevant (“projects”).
I.- Who is responsible for the processing of personal data?
The controller responsible for the processing of personal data is URSA INSULATION, SA, Paseo de Recoletos, 3, 28004 Madrid. Any reference to «we» or «us» in this data protection information is a reference to the aforementioned entity.
Our data protection coordinator may be contacted via the aforementioned means or via privacy.ursa@etexgroup.com.
II.- Which data do we process?
For the purposes of our business – namely for information about our products and services – we process data of our business partners. Insofar as these data allow conclusions to be drawn about a natural person (for example, if we process information about sole traders as business partners), these are personal data. Regardless of the legal form of our business partners, we also process data on the contact persons at our business partners.
Please make this data protection information available to the persons within your organization that are involved in the business relationship with us («contact persons»)
Basic data: We process certain general data concerning our business partners and the contact persons as well as the business relationship with us, collectively «basic data». Basic data include:
- all information about our business partner, which we ourselves or third parties can extract from publicly available sources about our business partner (such as name, address, other contact details and information about projects involving the respective business partner)
- the information provided to us by you or third parties working with you, if any, through a contact person (such as the details given on a business card given to us and the information provided to us in addition, such as a telephone call or telephone call) Meeting); as
- any information collected and processed by us in connection with the establishment of the business relationship (e.g., the details of the agreements entered into)
Performance data: We process personal data collected in the course of the business relationship other than by merely updating basic data and that we refer to as «performance data». Performance data include:
- information about the activities of our business partner (e.g. projects under involvement of our business partner), which we may extract ourselves or through third parties from publicly available sources
- information about the activity of our business partner, communicated to us by them or by third parties who work with them, possibly through a contact person
- Information about the projects planned or carried out with the participation of the respective business partner with regard to our products and services or the products and services of third parties.
III.- For which purposes and on which legal basis do we process your personal data?
We process basic, performance and usage data for the performance of the contractual relationships with our customers or for pre-contractual measures on the basis of Article 6 para 1 b) GDPR. Regardless of the legal form of our customers, we process basic and performance data concerning one or more contact persons for the purpose of our legitimate interest in the performance of the business relationship on the basis of Article 6 para 1 f) GDPR.
We may process basic, performance and usage data also for compliance with legal obligations to which we are subject; this processing is based on Article 6 para 1 c) GDPR. Legal obligations may in particular include the mandatory disclosure of personal data to (tax) authorities.
To extent necessary, we process personal data (in addition to the processing for the purposes of the business relationship or to comply with legal obligations) for the purposes of our legitimate interests or the legitimate interests of a third party on the basis of Article 6 para 1 f) GDPR. Legitimate interest may include group-wide processes for internal administration of customer data the establishment of or defense against legal claims the prevention and investigation of criminal offences maintenance of security for our information technology systems the maintenance of security of our premises and infrastructure management and further development of our business operations including risk management
If we provide to a natural person the option to declare a consent in the processing of personal data, we process the personal data covered by the consent for the purposes specified in such consent on the basis of Article 6 para 1 a) GDPR.
Please note that the declaration of consent is voluntarily, that failure to declare consent or the withdrawal of a consent may, nevertheless, have consequences, and we will inform about such consequences before you are given the option to declare your consent consent may be withdrawn at any time with effect for the future, e.g. by providing notice to us via mail, fax, email using the contact information specified on the first page of this data protection notice.
IV.- Is there an obligation to provide personal data?
The provision of the basic and performance data specified in section II above is necessary for entering into and maintaining a business relationship with us, unless specified otherwise before or at collection of the data. Without the provision of these data, were are not able to enter into and maintain a business relationship.
Please also note our advice on the right to object to the processing of personal data in order to safeguard legitimate interests in para. IX.
If we collect additional data, we will indicate if the provision of such information is based on a legal or contractual obligation or necessary for the performance of an agreement. We usually indicate which information may be provided voluntarily and is neither based on a legal or contractual obligation nor necessary for the purposes of an agreement.
V.- Who has access to personal data?
Personal data are generally processed within our company. Depending on the categories of personal data, only dedicated departments / organizational units are granted access to your personal data. Such units include in particular the [#Sale department#] and – if data are processed via our IT infrastructure – also our IT department. Based on a role / rights management concept, access to personal data is limited to the functions and the extent necessary for the respective purpose of the processing.
If and to the extent permitted by law, we may transfer your personal data to recipients outside of our company. Such external recipients may include affiliated companies within Etex group, to which we may transfer personal data for the purpose of internal administration of employee data; other business partners to whom we may transfer personal information in order to safeguard the legitimate interests of the business partner to whom the data transmitted relates; service providers that – on the basis of separate agreements with us – provide certain services possibly including the processing of personal data, as well as approved subcontractors of our service providers; private or public bodies, to the extent we are obliged to transfer your personal data on the basis of a legal obligation to which we are subject.
VII.- Do we use automated decision-making?
In the course of the business relationship we generally do not use automated decision-making (including profiling) within the meaning of Article 22 GDPR. If we apply such processes in the future, we will inform data subjects separately in accordance with the applicable statutory provisions.
VIII.- Are data transferred to countries outside the EU / the EEA?
Personal Information that we collect may be transferred to, and stored at, any of Etex’s affiliates and service providers in countries outside the EEA which do not necessarily offer an adequate level of protection of your Personal Data.
We comply with applicable legal requirements for the above transfer of your Personal Information, including the implementation of appropriate safeguards to ensure its protection. This implies reliance on specific derogations and safeguards set out in the GDPR, including the relevant standard contractual clauses.
IX.- How long are your data stored?
We generally store personal data as long as we have a justified interest in the retention of such data and there the interest of the data subject in refraining from the further processing do not prevail.
Even without a justified interest, we may continue to store the data if there is a legal obligation (e.g. to comply with statutory retention obligations). We delete personal data even without an action by the data subject as soon as further retention is no longer necessary for the purposes for which the data were collected or otherwise processed or if further retention is not permitted by law otherwise.
In general, basic data and the additional data collected in the course of the business relationship at least until the end of the respective business relationship. The data are deleted in any case if the purposes for the collection or processing were achieved. This point in time may be after the end of the business relationship with us. If personal data need to be stored to comply with a legal obligation, such data is retained until the end of the respective retention period. If personal data are only processed to comply with a statutory retention obligation, the access to such data is usually restricted so that the data are only accessible if needed for the purpose of the retention obligation.
X.- What rights does an data subject have?
Right of objection according to Art. 21 GDPR
An data subject has the right, at any time for reasons arising from your particular situation, to object to the processing of his/ her personal data relating pursuant to Article 6 (1) (e) or (f) GDPR; this also applies to a profiling based on these provisions. In the event of such objection, we will no longer process the personal data concerning that person, unless we can demonstrate compelling legitimate reasons for processing that outweigh the interests, rights and freedoms of the data subject, or the processing is for assertion, exercise or defense of legal claims.
When we process personal data to operate direct marketing, you have the right to object at any time to the processing of your personal data for the purposes of such advertising; this also applies to a profiling insofar as it is associated with such direct mail. If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.
A data subject may
- request access to his/her personal data, Article 15 GDPR
- request the rectification of incorrect personal data, Article 16 GDPR
- request the erasure of his/her personal data, Article 17 GDPR
- request the restriction of the processing of his/her personal data, Article 18 GDPR
- exercise the right to data portability, Article 20 GDPR
- object the processing of his/her personal data, Article 21 DSGVO.
The aforementioned rights may be asserted against us, e.g. by providing notice to us via the contact details specified on the first page of this data protection information.
In case of further questions, the data subject may also approach our data protection officer.
In addition, the data subject is entitled to lodge a complaint regarding the handling of personal data with the competent supervisory authority, Article 77 GDPR.
Data protection information marketing
We are committed to protect your personal data and comply with applicable data protection law, in particular the EU General Data Protection Directive («GDPR») and, and we only process your personal data on the basis of a statutory provision or if the data subject has declared consent.
In this data protection information, we provide you with the mandatory information on the processing of your personal data. In relation to this processing, we comply with applicable data protection law, in particular the EU General Data Protection Regulation («GDPR«).
- Who is responsible for the processing of personal data?
The controller responsible for the processing of personal data is URSA INSULATION, SA, Paseo de Recoletos, 3, 28004 Madrid. Any reference to «we» or «us» in this data protection information is a reference to the aforementioned entity.
Our data protection coordinator may be contacted via the aforementioned means or via privacy.ursa@etexgroup.com.
- Which data do we process? For which purposes and on which legal basis do we process your personal data?
We would like to inform you about products, services, offers and promotions. For this purpose, we offer you the opportunity to choose between different contact channels when you give your consent.
Depending on your choice of one or more contact channels, we will process the necessary data as provided by you in the contact form, at least your surname and first name and the details of the contact channel (post, e-mail, telephone, SMS) selected by you.
We process this personal data on the basis of your consent and according to Article 6 (1) a) DSGVO
III. Is there an obligation to provide personal data? Can I withdraw my consent?
You give your consent and choose your contact channel on a purely voluntary basis. You are therefore not obliged to provide personal data. In order that we can send you the information via the desired contact channel, we require the data marked as mandatory fields in the contact form.
You can revoke your consent at any time without giving reasons with effect for the future by simply contacting us. You will also find a link to unsubscribe in each e-mail.
- Who has access to personal data?
We will never sell your email address of other contact data to third parties. The data will only be transferred if this is necessary to send you our information. In this context, we can also commission external service providers and other group companys, taking into account the applicable statutory regulations.
We will only share your information with the following categories of recipients to prepare and send our information to you:
- Service providers within our group of companies (e.g. to provide statistical analysis and technical maintenance for our systems).
- External service providers who provide services on our behalf and on a separate contractual basis, such as collecting your data, hosting our websites, maintaining our call center, sending e-mails or written information or providing personal advice.
In addition, we may transfer data to other recipients (e.g. public authorities) to the extent we are obliged to transfer your personal data on the basis of a legal obligation to which we are subject
- Do we use automated decision-making?
In the course of our direct marketing activities we generally do not use automated decision-making (including profiling) within the meaning of Article 22 GDPR. If we apply such processes in the future, we will inform data subjects separately in accordance with the applicable statutory provisions.
- Are data transferred to countries outside the EU / the EEA?
Personal Information that we collect may be transferred to, and stored at, any of Etex’s affiliates and service providers in countries outside the EEA which do not necessarily offer an adequate level of protection of your Personal Data.
We comply with applicable legal requirements for the above transfer of your Personal Information, including the implementation of appropriate safeguards to ensure its protection. This implies reliance on specific derogations and safeguards set out in the GDPR, including the relevant standard contractual clauses.
VII. How long are your data stored?
- We generally store personal data as long as we have a justified interest in the retention of such data and there the interest of the data subject in refraining from the further processing do not prevail. Even without a justified interest, we may continue to store the data if there is a legal obligation (e.g. to comply with statutory retention obligations). We delete personal data even without an action by the data subject as soon as further retention is no longer necessary for the purposes for which the data were collected or otherwise processed or if further retention is not permitted by law otherwise.
- As far as the aforementioned processing is concerned, we will store your personal data as long as you have not withdrawn your consent or indicated otherwise that you do not want to be provided with further information from us. Also in this case, we store your contact data in order to ensure that you are not contacted following your withdrawal or objection (so called blacklist).
- If personal data need to be stored to comply with a legal obligation, such data is retained until the end of the respective retention period. If personal data are only processed to comply with a statutory retention obligation, the access to such data is usually restricted so that the data are only accessible if needed for the purpose of the retention obligation.
VIII. What are your rights as a data subject?
As a data subject you may
- request access to your personal data, Article 15 GDPR
- request the rectification of incorrect personal data, Article 16 GDPR
- request the erasure of your personal data, Article 17 GDPR
- request the restriction of the processing of your personal data, Article 18 GDPR
- exercise the right to data portability, Article 20 GDPR
- object the processing of your personal data, Article 21 DSGVO.
The aforementioned rights may be asserted against us, e.g. by providing notice to us via the contact details specified on the first page of this data protection information.
In case of further questions, you may also get in touch with our data protection coordinator by sending an e-mail to: privacy@ursa.com.
In addition, the data subject is entitled to lodge a complaint regarding the handling of personal data with the competent supervisory authority, Article 77 GDPR.
Data Protection Information job applicants data
We are committed to protect your personal data contained in your curriculum vitae (CV) and to comply with applicable data protection law, in particular, the EU General Data Protection Regulation («GDPR«) and we only process your personal data on the basis of a statutory provision or if you have declared your consent.
In this data protection notice, we explain which information (including personal data) is processed by us once we have received your CV in the “career section” of our web page www.ursa.com or at the reception desk of our premises.
- Who is responsible for the processing of personal data?
The controller responsible for the processing of your personal data is Ursa Insulation, S.A., Paseo de Recoletos, 3, 28004 Madrid, Spain (hereinafter, Ursa). Therefore, any reference to «we» or «us» in this data protection information is a reference to the aforementioned entity.
Our data protection coordinator may be contacted via the aforementioned means or via privacy.ursa@etexgroup.com.
- Which data do we process?
The storage and use of your CV for future recruitment processes requires the processing of the personal data contained in your CV. This treatment will be «automated» for CVs received through the “career section” of our web page and «not automated» for CVs received at our facilities in paper format.
Ursa will process any information you have included in the web form and in your CV – in general, gender treatment, name, surname, address, telephone number, email address, date of birth, marital status, nationality, national identity card/ passport number, information on your education and previous employment, and aspects of personality, behavior or skills. The preceding categories of data may include special categories of personal data in the sense of Article 9.1 GDPR, such as your photograph, only whenever they are provided by you.
III. For which purposes and on which legal basis do we process your personal data?
We process the data contained in the “career section” and in your CV to keep you informed of the different job vacancies in our organization, as well as to evaluate you as a candidate in our personnel selection processes.
We process your data on the basis of Article 6.1(a) GDPR, i.e., on the basis of your consent. If the consent refers to special categories of personal data (such as health data), the processing is based on Article 9.2(a) GDPR.
Please note that the declaration of your consent is always voluntary. However, your lack of consent will make it impossible for us to keep your CV and process any of the personal data included in it. You may withdraw your consent at any time with effect for the future, e.g. by providing notice to us via mail or email using the contact information specified in the first section of this data protection notice.
- Are you obliged to provide data?
The provision of the data contained in your CV is necessary for storing the same and use the data within the context of future recruitment processes in our company. Without the provision of these data, were will not able to use your CV future recruitment processes.
- Who obtains or has access to your data?
Your personal data are generally processed within our company and particularly by our Human Resources Department. The department concerned by the selection process may have access to your personal data as well.
If and to the extent permitted by law, we may transfer your personal data to recipients outside of our company. Such external recipients may include
- affiliated companies within the Etex group, which Ursa belongs to;
- recruitment services providers; and
- private or public bodies, to the extent we are obliged to transfer your personal data on the basis of a legal obligation to which we are subject.
- Do we use automated decision-making?
In the course of the recruitment process and the employment relationship, we do not use automated decision-making (including profiling) within the meaning of Article 22 GDPR. If we apply such processes in the future, we will inform you separately in accordance with the applicable statutory provisions.
VII. Are data transferred to countries outside the EU / the EEA?
Personal Information that we collect may be transferred to, and stored at, any of Etex’s affiliates and service providers in countries outside the EEA which do not necessarily offer an adequate level of protection of your Personal Data.
We comply with applicable legal requirements for the above transfer of your Personal Information, including the implementation of appropriate safeguards to ensure its protection. This implies reliance on specific derogations and safeguards set out in the GDPR, including the relevant standard contractual clauses.
VIII. How long are your data stored?
We keep personal data for a maximum of one year after receiving your CV.
We will cease to keep your personal data at the end of this maximum period unless you inform us before that date of your interest in the cessation of such processing by our company. In addition, we delete your personal data as soon as further retention is no longer necessary for the purposes for which the data were collected or otherwise processed or if further retention is not permitted by law otherwise.
In the event that the applicant is finally selected to become a member of the Ursa workforce, we inform you that we will keep and process the personal data contained in your CV for the entire duration of the employment relationship, except in the event that the personal data need to be stored beyond that time to comply with a legal obligation, in which case such data is retained until the end of the respective legal retention period.
- What are your rights as a data subject?
As a data subject, you may
- request access to your personal data, Article 15 GDPR;
- request the rectification of incorrect personal data, Article 16 GDPR;
- request the erasure of your personal data, Article 17 GDPR;
- request the restriction of the processing of your personal data, Article 18 GDPR;
- exercise your right to data portability, Article 20 GDPR;
- object the processing of your personal data, Article 21 GDPR.
The aforementioned rights may be asserted against us, e.g. by providing notice to us via the contact details specified on the first section of this data protection information notice, sheet, together with a copy of your Identity Card or equivalent identification document. In case of further questions, you may also get in touch with our data protection coordinator by sending an email to via privacy.ursa@etexgroup.com.
In addition, if you consider that your data are not correctly treated by our company or that your requests to exercise rights have not been satisfactorily attended, you are entitled to lodge a complaint regarding the handling of your personal data with the competent supervisory authority, Article 77 GDPR.
- Personal data security and confidentiality
In order to safeguard the security of your personal data, we inform you that Ursa has adopted all the necessary technical and organizational measures to guarantee the protection of the personal data provided. All of the foregoing aimed at avoiding their alteration, loss, and/or unauthorized processing or access, as required by law.
We inform you that your data will be treated with the maximum confidentiality by all the personnel involved in any of the phases of the treatment.