1.Introduction
1. Introduction
The right to privacy and, in particular, the right to personal data protection is one of the basic principles of the companies that compose the Seabery Augmented Technology SL group (henceforth “Seabery”) with registered offices at Doctor Emilio Haya Prats Street, 13, 21005, Huelva, Spain, and it is included in its Ethics Code.
The purpose of this General Privacy Policy (henceforth, “the Policy”) is to explain the way Seabery will use the personal information that may be collected through the site https://www.seaberyat.com/ (the “Website”), our personal data protection policy and it is provided with the information required by the regulations applicable to the Services of the Information Society and Electronic Commerce, and in accordance with that information you may voluntarily decide to what extent you wish to provide your personal data.
Your personal data will be treated as strictly confidential, and only for the purposes you agreed to, as explained below and detailed in each specific privacy policies of each form, as the case may be.
2. Scope of the Policy
This Policy applies only to this Website, and not to websites owned by third parties. From this Website, Seabery may provide links to other websites that it considers of interest to its visitors. Seabery wants to ensure that these sites maintain the highest standards of protection.
However, given the natures of the Internet, Seabery cannot guarantee the privacy levels of such web sites, nor be responsible for the contents of the websites outside the Seabery property. This Policy is not intended to be applied to any non-group site linked to by Seabery.
3. Commitment to privacy
Seabery is fully committed to regulatory compliance, specially to the EU GDPR, and the regulations related to the protection of personal data in force at any given time.
For this reason, Seabery has implemented these principles, being privacy the basis for them:
- Transparency in data treatment is one of Seabery’s priorities, that is why, every time personal data is needed, the user will be properly informed thanks to the applicable privacy policy, including, among other aspects, the objective of the given processing.
- The processing of the personal data strictly necessary to provide the service requested, if any.
- The accessibility and proactivity, whenever possible, to provide you with simple means to control your personal data.
- The non-transfer of your personal data to third parties, with the exception of Seabery’s suppliers, or to those that Seabery previously informed and received consent to.
- The confidentiality of the personal data collected and processed by Seabery, guaranteeing the adoption of the proper security measures for their protection.
4. Controller
“Seabery Augmented Technology, S.L.”, company based in Huelva, Spain, Doctor Emilio Haya Prats Street, 13, 21005, with Tax number B-21.568.878 (onwards, the “Company”) is the controller of the personal data.
If you have any questions regarding the processing of your personal data, you can contact the Company through the following channels:
(i) Email to the following address info@www.seaberyat.com
(ii) Postal mail addressed to Seabery, C / Doctor Emilio Haya Prats, 13 21005, Huelva (Spain).
4. Purposes of the processing
The Company gathers user’s personal data provided through the forms available on the Website, via e-mail or in the communications of the users by other means, in order to process their requests and provide services and products that may be of their interest. The Company and the other companies that compose Seabery group process these personal data for the following purposes:
a) Attend to the enquiries, questions or requests made through the customer service or communication channels identified on the Website, and contact the user to resolve them.
b) Improve the Website, as well as the Company’s services and product in order to offer better services and contents.
c) Provide access to restricted areas of the Website (Registration may require the acceptance of a specific privacy policy).
d) Allow you to make purchases through the Website.
e) Conduct studies for statistical purposes.
f) Comply with tax obligations.
g) Process the guarantee of the products purchased from Seabery.
h) Comply with the current legal framework.
i) Manage the user’s data to send commercial information.
j) Collect, store and process his/her CV as well as the personal data included therein, with the aim of analysing your professional profile to involve the user in Seabery’s selection processes.
k) Send communications by e-mail and/or telephone and/or postcards in the personal selection process by Seabery.
l) Asses their ability to perform a job by carrying out specific tests that will be communicated to them in due course.
You are also informed that no profiles or segmentations will be created, and that no automated decisions will be made about the data provided by users.
In the hypothetical case that you provide your data through an e-mail message, it will form part of a data processing whose purpose will be the management of the request, suggestion or comment that you make to us.
5. Personal data categories
Seabery will only collect personal data that you voluntarily wish to disclose and, in accordance with current legislation on data protection, as well as on information society and e-commerce services, will inform you that such personal data provided at the time of registration, or any other data provided to Seabery for access to any of the services on the Website, will be incorporated into files owned by Seabery.
The categories and/or kinds of personal data processed by Seabery are those directly provided by the data subject, owner of such data. Particularly, the data that Seabery could request from you are the followings:
- Identification data/strong> Information concerning a natural person that allows to differentiate it from others in a community, such as: name; handwritten and electronic signature; tax identification number; place and date of birth; nationality; photography; age.
- Contact information Information that allows you to keep in touch with its owner, such as: address; e-mail; landline phone; cell phone.
- Data on physical characteristics. Information about a natural person relating to his or her physiognomy, anatomy, specific features or particularities, such as: measures necessary for the manufacture of the products.
- Financial or patrimonial data. Information concerning a natural person relating to his or her assets, rights, charges or obligations subject to economic valuation, such as: bank accounts, credit card number, security number.
6. Legitimacy of the processing of your personal data: legal basis
The legal bases for the processing of your data by Seabery are as follows:
a) In case users request for services and/or information, the legal basis is the legitimate interest of the Company in the correct management of the request for services and/or information made by users.
b) In case users send the CV through the forms available on the Website, with the aim of analyzing its professional profile to involve the users in Seabery’s selection processes, the legal basis is the express consent of the users given by click[1] in acceptance of the Policy required to send the CV.
b) In case users provide any data on physical characteristics or any other sensitive or specially protected data the legal basis is the express consent of the users. Consequently, Seabery DOES NOT process sensitive or specially protected data without express consent of the users, so if users provide such data to the Company and no express consent by the users has been granted, it will be destroyed immediately.
The processing of your personal data may sometimes be necessary to comply with certain legal obligations, or in relation to any contractual relationship that SEABERY may have with you.
In all other cases, and whenever appropriate, Seabery will request your consent to process your personal data.
7. Sending commercial communications.
SEABERY, within the framework of its promotional activity, can provide resources for the registration or subscription to news or commercial information related to the Seabery Group. These resources will always be subject to your express consent to remit them.
In the event that you have expressly authorized it, Seabery will send you information about its products, activities and personalized services, according to your tastes and preferences. Likewise, and in the case, that you have also expressly consented to it, you may receive information related to the contests and / or draws of Seabery, as well as your events and corporate events close to your location.
You can revoke your consent to receive commercial communications at any time, through the link or button enabled for this purpose in each of the communications, or directly communicating your willingness to revoke the consent through the following channels:
(i) Email to the following address info@www.seaberyat.com
(ii) Postal mail addressed to Seabery, C / Doctor Emilio Haya Prats, 13 21005, Huelva (Spain).
8. Duration of processing and data retention period.
Seabery is committed to treating your personal data as long as it is really useful and necessary in order to provide you with a quality service by processing it. Therefore, SEABERY will make every reasonable and timely effort to minimize the processing and retention of your personal data.
The data will be conserved depending on the categories and/or kinds of personal data processed[2]:
a) General data: the data will be kept as long as the relationship with the users remains active, at least for a period of five (5) years since the last interaction and as long as no liability has been prescribed, during which time they will remain blocked.
b) Job seekers data: the data will be kept as long as the duration of the selection process for the job for which the users have applied, being able to keep them subsequently blocked for three (3) years.
In any case, and even if you request the deletion of your personal data, Seabery will have the right to keep and maintain them, under due blockade, during the necessary period to comply with the corresponding legal obligations, as well as to make them available to the competent authorities in the different subjects that are applicable.
8. Data communications
The Company may share personal data with its affiliates or with the service providers of Seabery in the systems and technology and administrative management sectors which may have access to the personal data of the users as part of the provision of services by such third parties to the Company and/or to the other companies that compose Seabery group.
The personal data of the users may be transferred to companies providing technological services and maintenance of Seabery’s systems located outside the European Union (“EU”). If you wish to know the countries where these companies are located, please write an email to the following address: info@www.seaberyat.com, and you will be provided with an updated list.
These transfers would be made on the basis of the subscription with such companies located outside the EU of standard data protection clauses adopted by the European Commission for international transfers as provided for in article 46.2 of the GDPR and/or to countries to which the European Commission considers that they offer adequate guarantees for the protection of your data. In case you would like to request a copy of these contractual clauses and/or the countries to which your data may be transferred, please contact the Company at the following email address to submit your request: info@www.seaberyat.com.
Your data will only be transferred or communicated when the Company and/or the other companies that compose Seabery group are legally required to do so by the competent authorities, including judges and courts or State security forces.
9. Exercise of rights and claims before the AEPD
As a result of Seabery’s processing of your personal data, you have a number of rights under applicable law. Seabery provides you with a brief explanation of each right to facilitate your exercise:
a) Right of access: You will have the right to know the personal data that are processed by Seabery, as well as the purposes of such processing.
b) Right of rectification: Your data will always be yours, and as such, you can request the rectification of these at any time if the data that appear in Seabery’s records are erroneous.
c) Right to delete: You may request, at any time, that your personal data be deleted from Seabery’s files. However, and as previously indicated, you should bear in mind that in certain circumstances, compliance with the current legislation may prevent the effective exercise of this right.
d) Right to object: You may object to the processing of your personal data for any purpose for which we process your data, according to the privacy policies applicable in each case.
e) Right to limit treatment: You may request the limitation of treatment in the following cases:
- 1. When you consider that the information Seabery maintains about you is not correct or accurate;
- 2. When you feel that Seabery is not treating your data legitimately, you prefer to limit the treatment of your data to its deletion;
- 3. When the data that Seabery maintains is no longer needed for the purpose for which it was collected, but you need to keep it to file legal claims;
- 4.When, having exercised the right of opposition to any treatment, it is pending a response from Seabery.
f) Right to data portability:
You have the right, whenever technically possible and reasonable, to request that the personal data you have provided directly be communicated to another data controller. If this is not possible, Seabery will provide your data directly to that other data controller, but if it is not possible, Seabery will provide it to you in a standard format.
If Seabery processes your personal data with your express consent, you may revoke it at any time, without any consequences for you beyond the fact that we may not be able to provide you with certain services in accordance with the law in force.
You may exercise your rights by contacting Seabery through one of the following means, together with a copy of your ID card or equivalent identification document:
(i) By e-mail to the following address: info@www.seaberyat.com
(ii) Postal mail addressed to Seabery, C/Doctor Emilio Haya Prats, 13 21005, Huelva (Spain).
If you do not wish to exercise a specific right, but need to make a query or suggestion regarding the processing of your personal data, you may also contact the addresses provided for the exercise of the rights.
Please note that, in any case, you may file a claim to the Competent Authority if you believe that Seabery has not treated your data lawfully or has not properly handled your requests or rights. In Spain, this Competent Authority is the Spanish Agency of data protection.
10. Confidentiality and Security in processing these data
Your personal data is very important to Seabery, so we are committed to treating it with the utmost confidentiality and discretion, as well as to implementing all the security measures that it deems appropriate and reasonable.
In this regard, Seabery declares and guarantees that it has established all the technical means at its disposal to prevent the loss, misuse, alteration, unauthorized access and theft of the data provided by users. Seabery also constantly reviews its security measures to ensure that they are always up to date.
11. Social Media
Social Networks are part of the everyday lives of many Internet users, and for this reason, it has been created different Seabery profiles on them.
All users have the opportunity to join the pages or groups that Seabery has on different social networks.
Please note, however, that unless we request your data directly from you (e.g. through marketing actions, contests, promotions, or any other valid means), your data will belong to the relevant Social Network.
Therefore, we recommend that you carefully read their terms of use and privacy policies, as well as make sure that you set your preferences regarding the processing of your data.
12. Information Society Services
In compliance with the provisions of the article 10 of Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce, you are provided with the following information:
a) Company name of information society service provider and Tax number: “Seabery Augmented Technology, S.L.” with Tax number B-21.568.878
b) Registration data: Registered in the Commercial Registry of Huelva in Volume 1.085, General Section of Companies Sheet number H-23.342, 1st Inscription.
c) Company address: Huelva, Spain, Doctor Emilio Haya Prats Street, 13, 21005.
d) E-mail address: info@www.seaberyat.com