Privacy Policy

PRIVACY and DATA PROTECTION POLICY

Introduction:

This Privacy Policy has been developed taking into account the provisions of the Organic Law on the Protection of Personal Data in force, as well as the Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the movement of such data, hereinafter the GDPR.
This Privacy Policy aims to bring to the attention of the holders of personal data, in respect of which information is being collected, the specific aspects relating to the processing of their data, among other things, the purposes of the processing, the contact details for exercising the rights to which they are entitled, the periods of conservation of the information and the security measures among other things.
Data Controller
In terms of data protection FENWICK IBERICA S.A. must be considered Data Controller, in relation to the files/processing identified in this policy, specifically in the section Data Processing.
The following is the identification data of the owner of this website: Data Controller: FENWICK IBERICA S.A. Postal address: Calle Bailen, 136, Entlo-2a 08037 Barcelona (Spain). E-mail address: info@fenwick-iberica.es.
Data processing
The personal data requested, if any, will consist only of those strictly necessary to identify and respond to the request made by the owner of these, hereinafter the person concerned.
Such information will be treated in a loyal, lawful and transparent manner in relation to the interested party. On the other hand, personal data will be collected for specific, explicit and legitimate purposes, and will not be further processed in a manner incompatible with those purposes. The data collected from each data subject shall be adequate, relevant and not excessive in relation to the purposes for which they are collected, and shall be updated whenever necessary.
The owner of the data will be informed, prior to the collection of their data, of the general points regulated in this policy so that they can provide express, precise and unequivocal consent for the processing of their data, in accordance with the following aspects.
Purposes of the processing.
The explicit purposes for which each of the treatments are carried out are included in the informative clauses incorporated in each of the ways of data collection (web forms, paper forms, locutions or posters and informative notes). However, the personal data of the interested party will be processed for the sole purpose of providing an effective response and meet the requests made by the user, specified next to the option, service, form or data collection system used by the owner.
Legitimation.
As a general rule, prior to the processing of personal data, FENWICK IBERICA S.A. obtains express and unequivocal consent of the owner of these, by incorporating informed consent clauses in the different information collection systems.
However, in the event that the consent of the data subject is not required, the legitimate basis for the processing on which FENWICK IBERICA S.A. relies is the existence of a law or specific regulation that authorizes or requires the processing of the data subject's data.
Addressees.
As a general rule, FENWICK IBERICA S.A. does not proceed to the transfer or communication of data to third parties, except those legally required, however, if necessary, such transfers or communications of data are informed to the person concerned through the informed consent clauses contained in the different ways of collecting personal data.
Origin.
As a general rule, personal data are always collected directly from the data subject, however, in certain exceptions, data may be collected through third parties, entities or services other than the data subject. In this regard, this will be communicated to the data subject through the informed consent clauses contained in the different information collection channels and within a reasonable period of time, once the data has been obtained, and at the latest within one month.
Retention periods.
The information collected from the interested party will be kept for as long as it is necessary to fulfill the purpose for which the personal data were collected, so that, once the purpose has been fulfilled, the data will be cancelled. Such cancellation will result in the blocking of the data being kept only at the disposal of the AAPP, Judges and Courts, to meet the possible liabilities arising from the treatment, during the period of limitation of these, fulfilled the said period will proceed to the destruction of the information. For information purposes, the following are the legal terms for the conservation of information in relation to different matters:

Navigation data.
In relation to the navigation data that may be processed through the website, in the event that data subject to the regulations are collected, it is recommended to consult the Cookies Policy published on our website. Rights of the interested parties. The data protection regulations grant a series of rights to the interested parties or data subjects, users of the website or users of the profiles of the social networks of FENWICK IBERICA S.A.
These rights granted to the interested parties are as follows:
- Right of access: the right to obtain information on whether their own data is being processed, the purpose of the processing being carried out, the categories of data being processed, the recipients or categories of recipients, the retention period and the origin of such data. - Right of rectification: the right to obtain the rectification of inaccurate or incomplete personal data.
- Right of erasure: the right to obtain the erasure of data in the following cases: o When the data is no longer necessary for the purpose for which it was collected o When the data subject withdraws consent o When the data subject objects to the processing o When the data must be erased in compliance with a legal obligation o When the data has been obtained by virtue of an information society service on the basis of the provisions of art. 8 para. 1 of the European Data Protection Regulation.
- Right to object: the right to object to a particular processing operation based on the data subject's consent.
- Right of restriction: the right to obtain the restriction of data processing in the following cases: o When the data subject contests the accuracy of the personal data, for a period of time that allows the company to verify the accuracy of the data. o When the processing is unlawful and the data subject objects to the erasure of the data. o When the company no longer needs the data for the purposes for which they were collected, but the data subject needs them for the formulation, exercise or defense of claims. o When the data subject has objected to the processing while it is being verified whether the legitimate reasons of the company prevail over those of the data subject.
- Right to portability: the right to obtain the data in a structured, commonly used and machine-readable format and to transmit it to another data controller when:
The processing is based on consent.
The processing is carried out by automated means.
- The right to lodge a complaint with the competent supervisory authority:
Interested parties may exercise the rights indicated above, by contacting FENWICK IBERICA S.A. by writing to the following address: Calle Bailen, 136, Entlo-2a 08037 Barcelona (Spain) indicating in the subject line the right you wish to exercise.
In this sense FENWICK IBERICA S.A. will respond to your request as soon as possible and taking into account the deadlines provided in the regulations on data protection.
Security.
The security measures adopted by FENWICK IBERICA S.A. are those required, in accordance with the provisions of Article 32 of the RGPD. In this sense, FENWICK IBERICA S.A., taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons, has established the appropriate technical and organizational measures to ensure the level of security appropriate to the existing risk.

In any case, FENWICK IBERICA S.A. has implemented sufficient mechanisms to:
1. guarantee the permanent confidentiality, integrity, availability and resilience of the processing systems and services.
2. Restore the availability and access to personal data quickly, in case of physical or technical incident.
3. Verify, evaluate and assess, on a regular basis, the effectiveness of the technical and organizational measures implemented to ensure the security of the processing.
4. Pseudonymize and encrypt personal data, if necessary.