1. INFORMATION TO THE USER
AMSTRO LEGAL SERVICES, S.A, as Data Controller, informs you that, in accordance with Regulation (EU) 2016/679 of 27 April (GDPR) and Organic Law 3/2018 of 5 December on the protection of personal data and guarantee of digital rights (LOPDGDD), we will process your data as set out in this Privacy Policy.
In this Privacy Policy we describe how we collect your personal data and why we collect it, what we do with it, with whom we share it, how we protect it, and your options regarding the processing of your personal data. This Policy applies to the processing of your personal data collected by the company for the provision of its services. If you accept the measures of this Policy, you agree that we will process your personal data as defined in this Policy.
2. CONTACT
Company name: AMSTRO LEGAL SERVICES, S.A.
Tax ID: A06975593
Address: Agustín de Foxá nº 4 2ºD, 28036 Madrid
DPO Contact: protecciondedatos@amstro.es
3. KEY PRINCIPLES
We have always been committed to providing our services with the highest degree of quality, which includes processing your data with security and transparency. Our principles are:
- Lawfulness: We will only collect your personal data for specific, explicit, and legitimate purposes.
- Data Minimization: We limit the collection of personal data to what is strictly relevant and necessary for the purposes for which it has been collected.
- Purpose Limitation: We will only collect your personal data for the stated purposes and only according to your wishes.
- Accuracy: We will keep your personal data accurate and up to date.
- Data Security: We apply appropriate technical and organizational measures proportionate to the risks to ensure that your data does not suffer damage, such as unauthorized disclosure or access, accidental or unlawful destruction or accidental loss or alteration, and any other form of unlawful processing.
- Access and Rectification: We have means for you to access or rectify your data when you deem appropriate.
- Retention: We retain your personal data lawfully and appropriately and only for as long as necessary for the purposes for which it has been collected. Regarding CVs from the “Join our team” section, if you accept this policy, we will retain it for one year for possible vacancies that may match your profile.
- International transfers: When your data is to be transferred outside the EU/EEA, it will be adequately protected.
- Third parties: Access and transfer of personal data to third parties are carried out in accordance with applicable laws and regulations and with appropriate contractual guarantees.
- Direct Marketing and cookies: We comply with applicable legislation on advertising and cookies.
4. COLLECTION AND PROCESSING OF YOUR PERSONAL DATA
The types of data that may be requested and processed are: Identification data, Contact data, and CVs. We also automatically collect data about your visit to our website as described in the cookie policy.
We collect and process your personal data for the purpose of:
- Responding to inquiries made through the web form: Legal basis: You give us your consent for processing purposes. You may of course withdraw your consent at any time.
- Providing information, services, products, relevant information, and news from AMSTRO: Legal bases:
- You have given us your consent for processing purposes. You may withdraw your consent at any time.
- There is a legitimate interest that is not undermined by your privacy rights, such as sending commercial information either by subscription to our newsletter or due to your status as a client.
- It is necessary for the provision of any of our services through a contractual relationship between you and us.
- Managing applications received through the “Join our team” form: Legal basis: You give us your consent for processing purposes. You may withdraw your consent at any time.
- Sending commercial communications and newsletters: Legal bases:
- You have given us your consent for processing purposes. You may withdraw your consent at any time.
- There is a legitimate interest that is not undermined by your privacy rights, such as sending commercial information either by subscription to our newsletter or due to your status as a client.
- It is necessary for the provision of any of our services through a contractual relationship between you and us.
5. DISCLOSURE OF PERSONAL DATA
Data may be disclosed to data processors. We only work with data processors that offer sufficient guarantees of compliance with current data protection legislation. Your personal data will in no case be processed from a country that does not offer a level of protection comparable to the European level. If it is decided to contract data processors located outside the European Economic Area, such contracting will be done in accordance with Chapter V of the General Data Protection Regulation.
By providing us with your data, you expressly consent to our disclosing it to those companies that are part of the GROUP, for the same purpose for which it was collected. No other disclosures of data to third parties are foreseen, except by legal obligation.
6. YOUR RIGHTS
In relation to the collection and processing of your personal data, you may contact us at any time to:
- Access your personal data and any other information indicated in Article 15.1 of the GDPR.
- Rectify your personal data that is inaccurate or incomplete in accordance with Article 16 of the GDPR.
- Erase your personal data in accordance with Article 17 of the GDPR.
- Restrict the processing of your personal data in accordance with Article 18 of the GDPR.
- Request the portability of your data in accordance with Article 20 of the GDPR.
- Object to the processing of your personal data in accordance with Article 21 of the GDPR.
If you have given your consent for any specific purpose, you have the right to withdraw the consent given at any time, without affecting the lawfulness of processing based on consent prior to its withdrawal.
You may exercise these rights by sending a reasoned and documented communication, by means of a written statement, attaching a photocopy of your ID card or equivalent identification document, addressed to the email address protecciondedatos@amstro.es. You also have the right to file a complaint with the competent supervisory authority (www.aepd.es) if you consider that the processing does not comply with current regulations.
7. LEGAL INFORMATION
The requirements of this Policy supplement, and do not replace, any other existing requirements under applicable data protection law, which shall prevail in any case. This Policy is subject to periodic reviews and the company may modify it at any time. When this occurs, we will notify you of any changes and ask you to re-read the most recent version of our Policy and confirm your acceptance.
PROCESSING ACTIVITIES IDENTIFIED AT AMSTRO LEGAL SERVICES, S.A
1. CLIENT PROCESSING
| Controller | AMSTRO LEGAL SERVICES, S.A. – Tax ID: A06975593 Agustín de Foxá nº 4 2ºD 28036 Madrid Telephone: (+34) 91.432.16.70 / 93.122.27.77 Email: info@amstro.es |
| Purpose | We process the information provided by clients to register them in our system for proper accounting, tax, and administrative client management and order invoicing. |
| Retention | The data provided will be retained until you exercise the right to erasure. In any case, they will be kept for the years necessary to comply with legal obligations. |
| Legal Basis | The existing contractual or commercial relationship covered by Article 6.1 of the GDPR. |
| Recipients | They may be disclosed to data processors with sufficient guarantees. No transfers outside the EU that do not offer a comparable level are foreseen, nor other disclosures to third parties except by legal obligation. |
2. SUPPLIER PROCESSING
| Controller | AMSTRO LEGAL SERVICES, S.A. – Tax ID: A06975593 Agustín de Foxá nº 4 2°D, 28036 Madrid Telephone: (+34) 91.432.16.70 / 93.122.27.77 Email: info@amstro.es |
| Purpose | We process the information provided by suppliers to register them in our system for proper accounting, tax, and administrative management and order invoicing. |
| Retention | They will be retained until you exercise the right to erasure and for the years necessary to comply with legal obligations. |
| Legal Basis | The existing contractual or commercial relationship covered by Article 6.1 of the GDPR. |
| Recipients | They may be disclosed to authorized data processors. No disclosures to third parties are foreseen except by legal obligation. |
3. PERSONNEL MANAGEMENT PROCESSING
| Controller | AMSTRO LEGAL SERVICES, S.A. – Tax ID: A06975593 Agustín de Foxá nº 4 2ºD, 28036 Madrid Telephone: (+34) 91.432.16.70 / 93.122.27.77 Email: info@amstro.es |
| Purpose | Development and maintenance of your employment relationship with the employing company (Selection, Recruitment, labor control under the Workers’ Statute, and risk prevention). |
| Retention | They will be retained until you exercise the right to erasure and for the years necessary due to legal obligations. |
| Legal Basis | Compliance by the company with current labor regulations. Different purposes will require prior consent. |
| Recipients | They may be disclosed to competent public administrations and regulated data processors. No other disclosures are foreseen without consent or legal obligation. |
4. TIME TRACKING PROCESSING
| Controller | AMSTRO LEGAL SERVICES, S.A. – Tax ID: A06975593 Agustín de Foxá nº 4 2ºD 28036 Madrid Telephone: (+34) 91.432.16.70 / 93.122.27.77 Email: info@amstro.es |
| Purpose | Time tracking of workers by legal requirement. |
| Retention | 4 years as indicated by current legislation in force. |
| Legal Basis | Article 34.9 of the Workers’ Statute. |
| Recipients | Authorized data processors. No other disclosures are foreseen except by legal obligation. |
5. BUSINESS DEVELOPMENT PROCESSING
| Controller | AMSTRO LEGAL SERVICES, S.A. – Tax ID: A06975593 Agustín de Foxá nº 4 2ºD, 28036 Madrid Telephone: (+34) 91.432.16.70 / 93.122.27.77 Email: info@amstro.es |
| Purpose | Send you corporate and commercial information from AMSTRO that may be of interest to you. |
| Retention | Until the revocation of consent by the data subject. |
| Legal Basis | Express consent. |
| Recipients | Data processors under the GDPR framework. No other disclosures are foreseen except by legal obligation. |
6. WHISTLEBLOWING CHANNEL PROCESSING
| Controller | AMSTRO LEGAL SERVICES, S.A. – Tax ID: A06975593 Agustín de Foxá nº 4 2°D, 28036 Madrid Telephone: (+34) 91.432.16.70 / 93.122.27.77 Email: protecciondedatos@amstro.es |
| Purpose | Protect workers (internal/external) or third parties who report regulatory violations through the internal channel in accordance with Law 2/2023. |
| Retention | Time essential to decide on the investigation. If not truthful, immediate erasure (except criminal offense). After 3 months without initiating an investigation, they will be erased, except to leave evidence of the system. Communications without follow-up will be recorded in anonymized form. |
| Legal Basis | Compliance with a legal obligation (Art. 6.1.c GDPR and mandatory implementation according to Law 2/2023). |
| Recipients | State Security Forces and Bodies, Courts and Tribunals (by requirement or crime). Authorized data processors. |
7. BUSINESS ACTIVITY COORDINATION (CAE) PROCESSING
| Controller | AMSTRO LEGAL SERVICES, S.A. – Tax ID: A06975593 Agustín de Foxá nº 4 12ºD, 28036 Madrid Telephone: (+34) 91.432.16.70 / 93.122.27.77 Email: protecciondedatos@amstro.es |
| Purpose | Business Activity Coordination Management. |
| Retention | The time necessary to comply with legal obligations. |
| Legal Basis | Compliance with a legal obligation (art. 24 PRL). |
| Recipients | Data processors. No other disclosures are foreseen except by legal obligation. |
8. DATA CENTER ACCESS CONTROL PROCESSING
| Controller | AMSTRO LEGAL SERVICES, S.A. – Tax ID: A06975593 Agustín de Foxá nº 4 2°D, 28036 Madrid Telephone: (+34) 91.432.16.70 / 93.122.27.77 Email: protecciondedatos@amstro.es |
| Purpose | Control of access to the data center room. |
| Retention | The time necessary to comply with legal obligations. |
| Legal Basis | Legitimate interest of the controller (art. 6.1.f GDPR). |
| Recipients | Data processors. No other disclosures are foreseen except by legal obligation. |
Common note for all processing activities regarding rights: Any person has the right to access, rectify, erase, restrict, or object to processing, as well as to the portability of their data by sending a written statement together with a photocopy of their ID card to protecciondedatos@amstro.es, or file a complaint with the AEPD.
