PRIVACY POLICY – ETHICS CHANNEL

Canal Ético Confidencial (Confidential Ethics Channel)  informs you that the personal information that you provide us by filling in this form will be processed by Finycar S.L. Registered in the Registro Mercantil of Madrid, in volume 35221, page 188 Section 8 and sheet 28792.

This privacy policy establishes the way in which personal information will be managed on this website. It is essential that you read and accept it before continuing to navigate.

Canal Ético Confidencial (Confidential Ethics Channel) is a professional service of Staylant Compliance S.L., with CIF: B21443940.  This company is linked to the Sorigué Group through the formalization of a service provision contract, through which the company of Grupo Finycar S.L. contract the Canal Ethico Confidencial service offered by Staylant Compliance S.L., who has the order by Finycar S.L. to carry out the processing of personal data necessary for the management of the Confidential Ethical Channel in the terms and conditions signed in the Contract formalized by both parties.

It should be noted that the circuit of personal data provided by users is configured in such a way that Finycar SL, is the Controller  of the personal data and  Staylant Compliance SL, as the manager of the professional service Ethical Channel Confidential, is the Processor.

Among the values with which we identify ourselves is transparency, for that reason we want you to know from the beginning, that the protection of your privacy in the processing of your personal data is an important concern to which we pay special attention. This Privacy Policy is meant to help you understand what data we collect and what we do with it. This is important; we hope you will take time to read it carefully before providing your personal data on this website.

Regarding users, those over the age of fourteen may register in the Confidential Ethical Channel as users without the prior consent of their parents or guardians.

In the case of children under the age of fourteen, the consent of the parents or guardians is required for the processing of their personal data.

We will never  collect any data regarding the professional situation, economic situation or the privacy of the other members of the minor´s family, without their consent.

As a user you should know that your rights are guaranteed, because in this website we respect and take care of the personal data of the users.

We have strived to create a safe and reliable space and for that reason we want to share with you our principles regarding your privacy:

  • We never collect personal data unless it is strictly necessary to be able to provide you with the services you request.
  • We never share personal information about our users with anyone, except to comply with the law or in case we have your express authorization.
  • Except as described in this privacy policy, we will not use your personal information for any other purpose.

It should be noted that this Privacy Policy could change depending on legislative requirements or self-regulation, so users are advised to visit it periodically. It will be applicable in the event that users decide to fill in a contact form of any of those available to them, where personal data is collected.

Confidential Ethics Channel has adapted this website to the requirements of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPDGDD), and Royal Decree 1720/2007, of December 21, known as the Regulations for the development of the LOPD. It also complies with the European Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons (RGPD), as well as with Law 34/2002, of July 11, of Services of the Information Society and Electronic Commerce (LSSICE or LSSI).

Information about the processing of your personal data

  • Identity of the Controller: Finycar S.L.
  • NIF/CIF: B78127438
  • Address: Av. General Perón, 38 28020 – MADRID
  • Trade name: Canal Ético Confidencial
  • Processor of your personal data: Stylant Compliance S.L.
  • Address: C/Mateo Inurria 11, 28036 – MADRID
  • Email: info@canaleticoconfidencial.com
  • Activity: Data processing services and complaints management.
  • Registered in the Registro Mercantil of Madrid, in volume 35133, page 163 and sheet 631831.

For the purposes of the provisions of the General Data Protection Regulation, the personal data you provide us through the forms on the website will receive the data processing of “High level users”.

For the data processing of our users, we implement all the technical and organizational security measures established in the current legislation.

Principles that we will apply to your personal information

In the processing of your personal data, we will apply the following principles that complies the requirements of the new European data protection regulation:

  • Principle of legality, loyalty and transparency: We will always require your consent to the processing of your personal data for one or more specific purposes that we will inform you in advance with absolute transparency.
  • Principle of data minimization: We are only going to request the strictly necessary data in relation to the purposes for which we require them.
  • Principle of limitation of the conservation period: the data will be retained for no longer than necessary for the purposes of the treatment, depending on the purpose, we will inform you of the corresponding conservation period, in the case of subscriptions we will review our listings periodically and we will eliminate those records that have been inactive for a long time.
  • Principle of integrity and confidentiality: The processing of personal data will be done with security and confidence. You should know that we take all necessary precautions to prevent unauthorized access or not appropriate use of our user´s data by third parties..

How have we collected your data?

The personal data that we processing in the Confidential Ethics Channel come from:

  • Contact Form
  • Complaint application form.
  • Comments on the blog.
  • Service request form.
  • Registration form as an affiliate.
  • Sales form.

WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR PERSONAL INFORMATION?

Anyone has the right to obtain confirmation on whether in Confidential Ethical Channel we are treating personal data that concerns them. Persons concerned have the right to:

  • Request access to personal data related to the concerned person.
  • Request the update of your personal information, modify it or delete it.
  • Request the limitation of your data processing.
  • Oppose the processing of your data.
  • Request the portability of your data.

The concerned persons can access their personal data, as well as request rectification of inaccurate data or request its deletion when, among other reasons, the data is no longer necessary for the purposes that were collected for. In certain circumstances, the persons concerned 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, the concerned persons may object to the processing of their data. Staylant Compliance, S.L. will stop processing the data, except for compelling legitimate reasons or the exercise or defense of possible claims.

As the person concerned, you have the right to receive the personal data that concern you, that you provided us and in a structured format, of common use and mechanical reading, and to transmit it to another person responsible (Data Controller) for the data processing when:

  • The data processing is based on consent.
  • The data has been provided by the person concerned.
  • The data processing is done by automated means.

By exercising your right to the portability of the data, you will have the right to transmit your personal data directly from Data Controller to Data Controller when it is technically possible.

The concerned persons will also have the right to an effective judicial protection and to present a claim to the supervisory authority,it means, the Spanish Agency for Data Protection,in this case,  if they consider that the processing of personal data that concerns them violates the Regulation.

For what purpose do we process your personal data?

When a user connects with this website to make a enquiry or communicate a complaint, he is providing personal information. Canal Ético Confidencial (Ethical Channel Confidence) is responsible for that information. This information may include personal data such as your IP address, name, physical address, email address, telephone number, and other information. By providing this information, the user gives their consent for their information to be collected, used, managed and stored by the Canal Ético Confidencial (Ethical Channel Confidence), only as described in the Legal Notice and in this Privacy Policy.

In Canal Ético Confidencial (Ethical Channel Confidence) there are different systems for collecting personal information provided by the concerned persons for each capture system or forms used:

  • Contact form: We request the following personal information: Name, Email, to respond to the requirements of users of Canal Ético Confidencial .com. For example, we can use these data to respond to your request and respond to any doubts, complaints, comments or concerns you may have regarding the information included in the web, the services provided through the web, the treatment of your personal data, questions referring to the legal texts included in the web, as well as any other queries that you may have that are not subject to the contracting conditions. We inform you that the data you provide us will be located on the servers of Telefónica S.A.

See privacy policy of Telefónica S.A. within the EU.

  • Service request form: We request; Name, Email, Phone, Address, to request any of the services that Confidential Ethical Channel makes available to its users. The information collected will allow requesting the corresponding service for a possible offline processing of it. The requests will always be answered through the internal system through a unique username and password for the complainant. We inform you that the information you provide us will be located on the servers of Telefónica S.A .. See privacy policy of Telefónica S.A. within the EU.

There are other purposes for which we process your personal data:

  • To guarantee compliance with the conditions of use and applicable law. This may include the development of tools and algorithms that help this website to guarantee the confidentiality of the personal data it collects.
  • To support and improve the services offered by this website.
  • We also collect other non-identifying data obtained through some cookies that are downloaded to the user’s computer when browsing this website that we detail in the cookie policy.

In accordance with the provisions of the RGPD), Finycar S.L. will be the Controller of the data corresponding to users of the website and subscribers, and  Staylant Compliance, S.L. will be the data Processor.

Canal Ético Confidencial, does not sell, rent or transfer personal data, nor will it in the future, to third parties without prior consent. However, in some cases collaborations can be made with other professionals, in those cases, consent will be required from users informing about the identity of the collaborator and the purpose of the collaboration. It will always be done with the strictest safety standards.

Legitimation for the processing of your data

The legal basis for processing your data is the required consent with this privacy policy.

The professional processing of the complaint management service is based on the consent that is requested, without in any case the withdrawal of this consent conditions the execution of the subscription contract.

Data category

The categories of data that are treated are identifying data, these are specially protected data.

How long will we keep your data?

The personal data provided will be kept as long as the report management relationship is maintained and will be deleted immediately after its termination.

To which recipients will your data be communicated?

To provide services strictly necessary for the development of the activity, Confidential Ethical Channel, shares data with the following service providers under their corresponding privacy conditions:

Hosting: Telefónica S.A. See privacy policy of Telefónica S.A. processes the data in order to perform its hosting services to Staylant Compliance, S.L.

Consultancy: Staylant Compliance, S.L. It is the legal firm responsible for the management and processing of the complaint in order to perform the services of processing and professional management of the complaint.

Website platform: Automattic Inc., with address in the USA. More information at: https://es.wordpress.com/. Automattic Inc. treats the data in order to perform its web platform services to Staylant Compliance, S.L.

Google Analytics: a web analytics service provided by Google, Inc., a Delaware company whose head office is at 1600 Amphitheater Parkway, Mountain View (California), CA 94043, United States (“Google”). Google Analytics uses “cookies”, which are text files located on your computer, to help Confidential Ethical Channel analyze the use made by users of the website. The information generated by the cookie about your use of Confidential Ethical Channel (including your IP address) will be directly transmitted and filed by Google on servers in the United States.

Email marketing: The Rocket Science Group LLC d / b / a, based in the US. More information at: http://mailchimp.com/ (The Rocket Science Group LLC d / b / a). The Rocket Science Group LLC d / b / a treats the data in order to perform its email marketing services to Staylant Compliance S.L

Navigation

When navigating through the Confidential Ethical Channel, non-identifiable data may be collected, which may include IP addresses, geographic location (approximately), a record of how services and sites are used, and other data that can not be used to identify the user. Among the non-identifying data are also those related to your browsing habits through third-party services. This website uses the following third-party analysis services:

  • Google Analytics

We use this information to analyze trends, administer the website, track the movements of users around the website and to collect demographic information about our user base as a whole.

Privacy and  Data Security

Canal Ético Confidencial is committed to using and processing users’ data, respecting their confidentiality and using the information in accordance with its purpose, as well as complying with their obligation to keep them and adopt all security measures to avoid alteration, loss, processing or unauthorized access, in accordance with the provisions of current data protection regulations.

This website includes an SSL certificate. It is a security protocol that allows your data to be transmitted in an integral and secure way, that is, the transmission of data between a server and a web user, and it´s totally encrypted.

Canal Ético Confidencial can not guarantee the absolute impregnability of the Internet network and therefore the violation of data through fraudulent access to them by third parties.

Regarding the confidentiality of the processing, Staylant Compliance, S.L. will ensure that any person who is authorized by the Confidential Ethical Channel to process customer data (including its staff, collaborators and providers), will be under an appropriate obligation of confidentiality (whether a contractual or legal duty).

When a security incident occurs, when the Canal Ético Confidencial becomes aware of it, it must notify the Controller without undue delay and must provide timely information related to the Security Incident as it is known or when the Controller reasonably requests it.

Accuracy and veracity of the data

As a user, you are the solely responsible for the veracity and accuracy of the data you send to the Canal Ético Confidencial, exonerating Staylant Compliance, S.L. (Canal Ético Confidencial), of any responsibility in this regard.

Users guarantee and respond for the accuracy, validity and authenticity of the personal data provided, and undertake to keep them properly updated. The user agrees to provide complete and correct information in the contact form or subscription form.

Acceptance and consent

The user declares to have been informed of the conditions on protection of personal data, accepting and consenting to the processing of the data by Staylant Compliance, S.L. (Canal Ético Confidencial) and Finycar, S.L, in the form and for the purposes indicated in this privacy policy.

Revocability

The consent given by the user, both for the processing and for the transfer of the data of the persons concerned, is revocable at any time by means of communication to Staylant Compliance, S.L. (Confidential Ethical Channel) in the terms established in this Privacy Policy for the exercise of the rights of access, rectification, cancellation, opposition, limitation, portability and not being subject to individualized decisions.. This revocation will not have retroactive effect.

Changes in the Privacy Policy.

Finycar S.L. and Staylant Compliance, S.L. reserves the right to modify this privacy policy to adapt it to new legislation or jurisprudence, as well as industry practices. In these cases, the changes introduced will be announced on this page in advance of its implementation.

Commercial emails

In accordance with the regulation contained in Law 34/2002, on Services of the Information Society and Electronic Commerce, Confidential Ethical Channel does not send commercial emails electronically.

Thank you, we appreciate the time you have spent reading this privacy policy.