PERSONAL DATA PROTECTION
Your data, your rights, our obligations
This document explains the data protection policy of Batlle (hereinafter BATLLE), which incorporates the principles of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter General Data Protection Regulation).
At BATLLE we fully embrace the spirit of this European Regulation, as it reinforces your rights and offers you more guarantees in relation to the processing of your data. This regulation makes the processing of your data uniform throughout Europe and establishes a framework of information and protection which we want you to be aware of.
For this reason, we summarize below the fundamental aspects of our data protection policy:
Who is responsible for the processing of personal data?
What is the role of the Data Protection Officer?
For what purposes do we process the data?
How do we get the data?
What is the legal basis for data processing?
To whom is the data communicated?
How long do we retain data?
What rights do individuals have in relation to the data we process?
How can rights be exercised or defended?
Specific data protection policies
Who is responsible for the processing of personal data?
The Data Controller is Batlle (BATLLE) email hola@batlle.es
The email address to send requests regarding the protection of personal data is hola@batlle.es
What is the role of the Data Protection Officer?
The Data Protection Officer (DPD) is the person who oversees compliance with our data protection policy, ensuring that data is handled appropriately and the rights of individuals are protected. His or her duties include addressing any queries, suggestions, complaints or claims from individuals whose data is processed. The Data Protection Officer can be contacted by writing to our postal address and telephone number, or directly by email. hello@batlle.es.
For what purpose do we process the data?
We process personal data with the rights of individuals in mind at all times and always in a proportional manner. This means that in each case we process the data that is appropriate, pertinent and required to fulfil the explicit purposes that motivated its collection; in short, only the data necessary to make it possible to provide Batlle's services.
In cases where you wish to obtain opinions or assessments about our services, more data than usual may be required. In these cases, the responses will be processed statistically and in a manner dissociated from the identifying data of the person who answers.
BATLLE processes personal data mainly to provide its services, to send communications related to its activities and services, to develop commercial relations with our environment, and ultimately, for our own management.
How do we get the data?
Data collection is achieved mainly through your contributions in the relationships established with the organization. The ways of conveying it can be through specific tools or methods for this purpose, such as digital or physical forms, interviews, recording images using security cameras, emails, etc.
What is the legal basis for data processing?
The legal basis that legitimizes the different data processing we carry out has different legal foundations, depending on the type of relationship and/or link existing with you. We classify the main data processing we carry out following the legal bases of article 6.1 of the General Data Protection Regulation.
Below we go into detail about each of these legitimations:
In compliance with a pre-contractual relationship:
This is the case of the data of people interested in the services offered by BATLLE.
For other reasons but with a similar legitimacy, we process the data of future employees, users of the services or suppliers with whom we have relationships prior to the formalization of a contractual relationship.
In compliance with a contractual relationship:
In the case of relations with our employees, suppliers and users of Batlle services, and all actions and uses of data that these contractual relationships entail.
In compliance with legal obligations:
Data is communicated, in compliance with legal obligations (tax regulations), to the tax administration, to judicial bodies or to security forces and bodies if required.
Based on the consent of the interested party:
When we send information about our activities or services, we use contact information with the explicit consent of the person who will receive it.
This is also the case for the processing of data of people who have sent us their CV or who participate in selective processes for job placement.
For legitimate interest:
The images obtained from video surveillance cameras are processed based on Batlle's legitimate interest in preserving assets and facilities.
Our legitimate interest also justifies the processing of the data we obtain from the contact forms.
To whom is the data communicated?
As a general rule, the personal data that we process at BATLLE, with the aim of achieving the purposes and taking into account the legitimations described previously, are only communicated based on compliance with legal obligations.
In the terms of the General Data Protection Regulation, this is not a transfer of data but rather a processing order. Services are only contracted from companies that guarantee compliance with this regulation. At the time of contracting, their confidentiality obligations are formalised and their performance is monitored. This may be the case for data hosting services on servers, IT support services, legal, accounting or tax consultancies.
Based on this, the following data communications ensure the correct development of existing contractual relationships, as well as compliance with legal obligations that require the aforementioned communications to be made:
How long do we retain data?
The retention period of data is determined by different factors. Firstly, the retention of data is affected by the fact that the data are still necessary to meet the purposes for which they were collected in each case. Secondly, they are kept to deal with possible responsibilities for the processing of data by BATLLE, and to meet any requirements from public administrations or judicial bodies.
Consequently, the data must be kept for the time necessary to preserve its legal or informative value and to prove compliance with legal obligations, but not for a period longer than necessary for the purposes of the processing (requirement of “limitation of the retention period” of the General Data Protection Regulation).
In certain cases, such as data contained in accounting and billing documentation, tax regulations require that they be kept until the responsibilities in this area expire.
In the case of data that is processed exclusively based on the consent of the data subject, it is retained until the data subject revokes this consent.
Finally, in the case of images obtained by video surveillance cameras, they are kept for a maximum of one month, although in the case of incidents that justify it, they are kept for the time necessary to facilitate the actions of the security forces or judicial bodies.
What rights do individuals have in relation to the data we process?
As provided for in the General Data Protection Regulation, the persons whose data we process have the following rights:
To know if they are treated:
First of all, anyone has the right to know whether we process their data, regardless of whether there has been a prior relationship.
To be informed at pick-up:
When personal data is obtained from the interested party, at the time of providing it, the interested party must have clear information about the purposes for which it will be used, who will be responsible for the processing and the main aspects arising from this processing.
To access:
Very broad right that includes the right to know precisely what personal data is being processed and the purpose for which it is being processed, the communications to other people that will be made (if applicable) or the right to obtain a copy or to know the expected term of conservation.
To the rectification:
It is the right to request the modification of any inaccurate data that is being processed by us.
Upon revocation:
In certain circumstances, there is a right to request the deletion of data when, among other reasons, they are no longer necessary for the purposes for which they were collected and their processing was justified.
To request limitation of treatment:
In certain cases, the right to request limitation of data processing is also recognised. In this case, the data will no longer be processed and will only be kept for the purpose of defending claims, in accordance with the General Data Protection Regulation.
To portability:
In the cases provided for in the regulations, the right to obtain personal data in a structured format for common use and readable by machines is recognised, as well as to transmit it to another data controller if the interested party so decides.
To opposition to treatment:
A person may give reasons related to their particular situation, facts that would lead to their personal data no longer being processed to the extent that it may cause harm to them, except for legitimate reasons, for the exercise or defence against claims.
Not to receive information:
We immediately respond to requests not to continue receiving information about our activities and services, when these messages were based solely on the consent of the recipient.
How can rights be exercised or defended?
The rights just listed can be exercised by means of a written request to BATLLE at the email address hola@batlle.es
In any case, whether to file complaints, request clarification or send suggestions, it is possible to contact the Data Protection Officer by email to the address hola@batlle.es
If you have not received a satisfactory response when exercising your rights, you may file a claim with the Catalan Data Protection Authority, using forms or other channels accessible from its website. https://apdcat.gencat.cat/es/inici/
