Privacy Policy
0. Our policy
At ASZENDE S.L.U. we care about privacy and transparency.
Below, we indicate in detail the processing of personal data that we carry out, as well as all the information relating to them.
as well as all the information related to them.
1. Data controller
- Identity: Aszende S.L.U.
- NIF: B08902892
- Postal Address: Calle Lima 7, 08030 Barcelona
- Telephone: 900 224 365
- E-mail: [email protected]
2. Personal data processing carried out by Aszende, S.L.U.
Processing of data of parties involved in the internal complaints channel
For what purposes do we process your personal data?
At ASZENDE, S.L.U., we process the information provided by the persons concerned in order to manage the internal complaints channel and the protection of persons who report breaches of regulations and the fight against corruption, with the aim of informing the person responsible of acts or conduct occurring in the entity or caused by third parties who contract with it, and which may be contrary to the general or sectoral regulations applicable to it. If you do not provide your personal data, we will not be able to fulfil the purposes described.
No automated decisions will be taken on the basis of the data provided.
How long will we keep your data?
The data processed may be kept in the information system only for the time necessary to decide whether to initiate an investigation into the facts reported (maximum three months). If it is established that the information provided or part of it is untrue, it shall be deleted immediately as soon as this is known, unless the untruthfulness may constitute a criminal offence, in which case the information shall be kept for the time necessary for the duration of the legal proceedings.
After three months have elapsed since the receipt of the communication without any investigation having been initiated, it shall be deleted, unless the purpose of storage is to leave evidence of the operation of the system. Communications that have not been processed may only be recorded in anonymised form, without the obligation to block provided for in article 32 of Organic Law 3/2018, of 5 December, being applicable.
The data shall be kept in the information register for the time necessary and proportionate and, in any case, for a maximum of ten years.
What is the legitimacy for the processing of your data?
- Compliance with a legal obligation: Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law (Art. 8; obligation of the establishment of internal whistleblowing channels – Law 2/2023 of 20 February regulating the protection of persons who report regulatory and anti-corruption breaches and Law 2/2023 of 20 February regulating the protection of persons who report regulatory and anti-corruption breaches).
- Consent of the data subject: For the storage, recording and/or recording of reports made via telephone line and voice messaging systems with recording, as well as for the recording/transcription of the personal meeting requested with the entity for the purpose of reporting (Directive (EU) 2019/1937; art. 18.2 and 4).
To which recipients will your data be communicated?
- State Security Forces and Corps; Jurisdictional Bodies; Public Prosecutor’s Office, for the purpose of reporting the commission of a possible crime (legal requirement).
- Data processors: companies providing the whistleblowing channel software, business management software and the company’s legal advisors.
Transfers of data to third countries
There are no plans to transfer data to third countries.
How did we obtain your data?
The personal data that we process at ASZENDE, S.L.U., comes from the complaint submitted by the interested parties who have an employment, commercial or service provision relationship with the company.
The categories of data processed are:
- Identification data.
- Commercial information.
- Financial data.
- Possible irregularities/illegal acts.
Special category data may be processed, e.g. health data.
Processing of job applicants' data
For what purposes do we process your personal data?
At ASZENDE, S.L.U., we process the information provided by interested parties in order to manage the CVs received and to carry out the personnel selection processes, interviews and other procedures necessary for the search for the best possible candidate and to send communications by e-mail informing you of the status of the candidacy for which you have applied. The data may also be used to send communications via WhatsApp, for the purpose of consulting the availability of interested parties to schedule interviews. No automated decisions will be made on the basis of the data provided.
How long will we keep your data?
Data will be deleted when the data subject requests deletion of his or her data or withdraws consent. When the data is obtained without an active application, the data will be kept for a maximum period of 1 year from the last interaction with the data subject, unless the data subject withdraws consent beforehand. Once the selection process has been completed, the data will be deleted, without prejudice to the retention of those that are necessary for the formalisation, development and execution of the employment relationship, being deleted when this ends and no liabilities can be derived for the company.
You must update your CV, updating the data entered in the form available on the web portal or sending it again if there are data that have undergone modifications or if you obtain new qualifications or certificates. Due to the principle of data accuracy we cannot store inaccurate or outdated CVs.
What is the legitimacy for the processing of your data?
- Execution of a contract or pre-contractual measures: management of CVs in order to carry out recruitment processes and search for the best possible candidate for a specific job for which there is a vacancy and an open recruitment process in which the data subject has applied (GDPR, art. 6.1.b). For the purposes of processing special category data, such as the degree of disability, the data controller is legally obliged to reserve a quota of 2% of jobs for disabled persons (GDPR, art. 9.2 b and RD Legislative 1/2013 General on the Rights of Persons with Disabilities and their Social Inclusion).
Legitimate interest of the data controller and the third party: sending communications by email or contacting by telephone informing you about the status of the application for which you have applied (RGPD, art. 6.1 f). The company has a legitimate interest, as these allow for efficient management of the selection process and keep the candidate informed about the progress of their application, fulfilling a reasonable expectation generated when applying for the vacancy. The use of these communication channels is a proportional and non-intrusive means of communication. This processing benefits both the company, which improves the candidates’ experience, and the data subject, who receives information on their status in the selection process.
As for the legitimate interest of the third party, which in this case is the candidate, it also lies in their right and expectation to receive information on the status of the vacancies for which they have applied, which allows them to make decisions regarding their professional career and plan their next steps based on the information received in the process.
- Consent of the data subject: storage of CVs sent by data subjects for the purpose of being considered for future vacancies (GDPR, art. 6.1.a).
- Consent of the data subject: sending communications via WhatsApp, for the purpose of consulting the availability of data subjects to schedule interviews (GDPR, art. 6.1 a).
To which recipients will your data be communicated?
Processors: company in charge of processing the hosting and maintenance of the registration platform for job applicants and business management software providers.
Transfers of data to third countries
There are no plans to transfer data to third countries.
How did we obtain your data?
The personal data that we process at ASZENDE, S.L.U., comes from the interested party.
Processing of customer data
For what purposes do we process your personal data?
At ASZENDE, S.L.U., we process the information provided by the interested parties in order to manage the purchase of products and/or services, monitor the status of the order, provide the services requested and carry out the administrative, accounting and tax management of the clients, as well as send commercial communications about our products and services. Where appropriate, manage the registration to the ‘Mi Aszende’ portal. If you do not provide your personal data, we will not be able to fulfil the purposes described.
No automated decisions will be made on the basis of the data provided.
How long will we keep your data?
The data will be kept for as long as the service is provided and the data subject does not request its deletion or deregistration from the web portal, if applicable, and, where appropriate, for the years necessary to comply with legal obligations. In relation to commercial communications, the data will be kept for as long as the data subject does not object to the processing or request its deletion.
What is the legitimacy for the processing of your data?
- Execution of a contract or pre-contractual measures: to manage the purchase of products and/or services, to monitor the status of the order, to provide the services requested and to carry out the administrative, accounting and tax management of customers (GDPR, art. 6.1.b).
- Legitimate interest of the Controller: sending commercial communications by electronic means (RGPD Recital 47, LSSICE art. 21.2).
Legitimate interest of the controller and the third party: to manage the registration to the web portal ‘My Aszende’. This portal allows customers to access relevant information about the contractual relationship in an efficient, secure and accessible manner.
From the perspective of the legitimate interest of the data controller, the provision of a portal that allows customers to view work reports, invoices, carry out other formalities or send suggestions is a means of centralising and facilitating access to information in an efficient, secure and accessible manner at any time. This reduces the administrative burden for both the company and the customer. By concentrating the relevant information on a centralised platform and avoiding the use of dispersed methods such as individual e-mails, telephone calls, etc., the portal provides a single access point where customers can find information related to their contractual relationship in an orderly and structured manner. By making their information available to the customer in a controlled and secure environment, the company can guarantee the integrity, availability and confidentiality of the personal data processed. This also minimises errors or problems arising from data dispersion, such as the risk of unauthorised access or loss of information.
For the customer, having such a portal means having a practical and accessible solution, which allows them to consult relevant information from the contractual relationship such as work reports, invoices and other data quickly and at any time, not only saving time, but also minimising possible errors or delays that may arise with more traditional methods of communication. The portal also acts as a channel that reinforces transparency in service delivery. The centralised portal also provides a controlled environment where information is protected from unauthorised access or loss. Compared to less secure alternatives, such as e-mails or paper formats, this digital tool allows customers direct and exclusive access to their information.
To which recipients will your data be communicated?
- Tax Administration, in order to comply with legal obligations (legal requirement).
- Financial institutions, for the purpose of payment of the price (contractual requirement).
- Data processors: Company in charge of processing the hosting and maintenance of the customer registration platform, business management software providers and the company’s legal, tax and accounting advisors.
Transfers of data to third countries
There are no plans to transfer data to third countries.
How did we obtain your data?
The personal data that we process at ASZENDE, S.L.U., comes from the interested party.
Processing of telephone recording data
For what purposes do we process your personal data?
At ASZENDE, S.L.U., we process the information provided by interested parties in order to record telephone calls in order to assess the quality of the service provided. If you do not provide your personal data, we will not be able to fulfil the purposes described.
No automated decisions will be made on the basis of the data provided.
How long will we keep your data?
The data will be kept for a maximum period of one year.
What is the legitimacy for the processing of your data?
Legitimate interest of the Controller and a third party: recording telephone calls to assess the quality of the service provided (GDPR, art. 6.1.f). The legitimate interest of the controller lies in ensuring and improving the quality of the service provided. This interest is essential to maintain customer satisfaction, to detect and correct deficiencies or incidents in the telephone service, and to ensure that quality standards are adequate. Evaluating the quality of service not only benefits the manager, but also the stakeholders, as it ensures an improved service and experience. In addition, in the case of incidents, the recordings serve as evidence of the events that occurred.
In the case of lift incident service recordings, they guarantee the safety of users in the event of incidents. In these cases, the priority is the physical and psychological well-being of those affected. Having a record of communications allows the person in charge to ensure that the incident is handled properly and efficiently, and that the affected persons receive the necessary attention without delays or errors.
In addition, recordings allow a level of traceability to be maintained that is essential in emergency contexts. Recording communications ensures that the procedures established to deal with these incidents are being followed correctly. In the event that complaints arise or there is a need to analyse how a specific situation was handled, these recordings act as objective evidence of what happened.
To which recipients will your data be communicated?
Administration of justice: dealing with requests and possible complaints (legal requirement).
State security forces: to deal with requests and possible complaints (legal requirement).
- Data processors: Customer service providers.
Transfers of data to third countries
There are no plans to transfer data to third countries.
How did we obtain your data?
The personal data that we process at ASZENDE, S.L.U., comes from the interested party.
Processing of data on potential customers and contacts
For what purposes do we process your personal data?
At ASZENDE, S.L.U., we process the information provided by interested parties in order to manage and deal with queries, claims, complaints or suggestions about our products and/or services by electronic and/or telephone means, and to send commercial communications by electronic means. If you do not provide your personal data, we will not be able to fulfil the purposes described. No automated decisions will be made on the basis of the data provided.
How long will we keep your data?
In case of processing based on the data subject’s consent, the data will be deleted once the consent is withdrawn for the purposes on which the consent is based or, where appropriate, or when the deletion is requested. For the processing of data based on legitimate interest, the data shall be retained as long as the data subject does not object to the processing. Professional contact data shall be retained for as long as business relations can be maintained and for a maximum period of 10 years from their collection or last interaction, unless the data subject objects.
What is the legitimacy for the processing of your data?
- Execution of a contract or pre-contractual measures: Management of potential customers who have expressed interest in our products and/or services (GDPR, art. 6.1.b).
- Legitimate interest of the Data Controller and a third party: To manage and deal with queries, claims, complaints or suggestions about our products and/or services by electronic or telephone means (GDPR, art. 6.1 f).
- Legitimate interest of the Data Controller: Management of professional contact data (LOPDGDD art.19, RGPD art. 6.1.f).
- Consent of the data subject: Sending commercial communications by electronic means about our products and/or services (RGPD, art. 6.1.a).
To which recipients will your data be communicated?
Data processors: business management software providers, customer service providers and, where appropriate, the company’s legal advisors.
Data transfers to third countries
No transfer of data to third countries is foreseen.
How did we obtain your data?
The personal data that we process in ASZENDE, S.L.U., come from the interested party.
Processing of supplier data
For what purposes do we process your personal data?
In ASZENDE, S.L.U., we process the information provided by interested parties in order to manage the provision of contracted services, perform the fiscal, accounting and administrative management of suppliers, as well as professional contact details. If you do not provide your personal data, we will not be able to fulfill the purposes described.
No automated decisions will be made based on the data provided.
How long will we keep your data?
The data will be deleted upon termination of the relationship with the supplier, always respecting the deadlines provided for by the tax legislation regarding the statute of limitations for liabilities. With regard to data processed for which the basis of legitimacy is the legitimate interest of the data controller, the data will be processed for as long as the data subject does not object to such processing. Professional contact data will be kept for as long as business relations can be maintained and for a maximum period of 10 years from their collection or last interaction, unless there is opposition from the data subject.
What is the legitimacy for the processing of your data?
- Execution of a contract or pre-contractual measures: to manage the provision of contracted services and to carry out the fiscal, accounting and administrative management of suppliers (RGPD, art. 6.1.b).
- Legitimate interest of the Controller: Management of professional contact data (LOPDGDD art.19, RGPD, art. 6.1.f).
To which recipients will your data be communicated?
- Tax Administration, in order to comply with legal obligations (legal requirement).
- Financial institutions, in order to make the corresponding payments (contractual requirement).
- Data processors: Business management software providers and legal, accounting and tax advisors of the company.
Data transfers to third countries
No están previstas transferencias de datos a terceros países.
How did we obtain your data?
The personal data that we process in ASZENDE, S.L.U., come from the interested party.
Processing of newsletter subscriber data
For what purposes do we process your personal data?
In ASZENDE, S.L.U., we process the information provided by the interested parties in order to send commercial communications electronically to the subscribers of our newsletters. If you do not provide your personal data, we will not be able to fulfill the purposes described.
No automated decisions will be made on the basis of the data provided.
How long will we keep your data?
The data will be kept as long as the data subject does not withdraw his consent or request deletion.
What is the legitimacy for the processing of your data?
Consent of the interested party: to send commercial communications by electronic means to the subscribers of our newsletters. By entering your data in the newsletter subscription form and selecting “send”, you are authorizing ASZENDE, S.L.U., to send you commercial communications by e-mail (RGPD, art. 6.1.a, and LSSICE art.21).
To which recipients will your data be communicated?
- Data processors: Business management software providers.
Data transfers to third countries
No transfer of data to third countries is foreseen.
How did we obtain your data?
The personal data that we process in ASZENDE, S.L.U., come from the interested party.
Processing of social network user data
For what purposes do we process your personal data?
In ASZENDE, S.L.U., we process the information provided by interested parties in order to send commercial communications to users who interact with the accounts of the responsible in social networks and manage communication with users who contact the responsible through their social networks. In the event that you do not provide your personal data, we will not be able to fulfill the purposes described.
No automated decisions will be made based on the data provided.
How long will we keep your data?
The data will be kept for as long as the data subject does not withdraw his/her consent or no longer follows the account of the data controller. For processing based on legitimate interest, the data will be deleted once the request has been fulfilled.
What is the legitimacy for the processing of your data?
- Consent of the interested party: Sending commercial communications to users who interact with the accounts of the responsible party in social networks. Following the accounts of RRSS of the responsible will involve the provision of consent to receive such communications (RGPD, art. 6.1.a).
- Legitimate Interest of the Controller and third parties: Management of requests from users who contact the Controller through its social networks (RGPD, art. 6.1.f).
To which recipients will your data be communicated?
No data will be transferred to third parties, unless legally required.
Data transfers to third countries
No transfer of data to third countries is foreseen.
How did we obtain your data?
The personal data that we process in ASZENDE, S.L.U., come from the interested party.
Data processing for the exercise of data subjects' rights
For what purposes do we process your personal data?
At ASZENDE, S.L.U., we process the information provided by the interested parties in order to manage and attend to the requests of the interested parties in the exercise of the rights established in the data protection regulations. If you do not provide your personal data, we will not be able to comply with the purposes described above.
No automated decisions will be made based on the data provided.
How long will we keep your data?
They will be kept for the time necessary to resolve the requests and for a maximum period of three years to attend possible claims.
What is the legitimacy for the processing of your data?
- Fulfillment of a legal obligation: to manage and respond to requests from data subjects in the exercise of the rights established in the data protection regulations (RGPD, art.6.1.b).
To which recipients will your data be communicated?
- Control authorities competent in the matter, in order to manage and respond to requests and possible claims (legal requirement).
- Data processors: business management software providers and legal advisors of the company.
Data transfers to third countries
No transfer of data to third countries is foreseen.
How did we obtain your data?
The personal data that we process in ASZENDE, S.L.U., come from the interested party.
3. Rights of the interested parties
Interested parties have the right to access their personal data, as well as to request the rectification of inaccurate data or, where appropriate, request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected. You also have the right to data portability.
In certain circumstances, interested parties may request the limitation of the processing of their data, in which case we will only keep them for the exercise or defense of claims.
In certain circumstances and for reasons related to their particular situation, interested parties may object to the processing of their data. In this case, ASZENDE, S.L.U., will stop processing the data, except for compelling legitimate reasons, or the exercise or defense of possible claims.
You may materially exercise your rights by contacting Calle Lima 7, 08030, Barcelona or by sending an e-mail to [email protected].
When sending commercial communications using as a legal basis the legitimate interest of the responsible, the person concerned may object to the processing of their data for that purpose.
If you have given your consent for a specific purpose, you have the right to withdraw the consent given at any time, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.
In case you feel that your rights concerning the protection of your personal data have been violated, especially when you have not obtained satisfaction in the exercise of your rights, you can file a complaint with the competent Data Protection Supervisory Authority through its website: www.aepd.es.