1. Who is responsible

¿Who is responsible for the processing of your data?

Owner: NECOMPLUS, S.L.
C.I.F.: B-03900099
Address: Avda. Doctor Jiménez Díaz 19, 1ª Planta Box 1
Telephone: 902 15 79 58
Contact Data Protection Delegate: lopd@necomplus.com

 

This policy also applies to NECOMPLUS PORTUGAL.
CIF: 507367359
Address: Centro Comercial da Qt. do Olho D’Água – Fracção D, Loja 4 Aveiro 3800-320
● E-mail: lopd@necomplus.com

This policy is also applicable to NECOMPLUS SERVEIS ANDORRA, S.L., based on the provisions of the COMMISSION DECISION of 19 October 2010 pursuant to Directive 95/46/EC of the European Parliament and of the Council on the adequate protection of personal data in Andorra.

● CIF: L-706092-U
● Address: AV. DEL PONT DE LA TOSCA Nº 1 – LOCAL 1, ESCALDES-ENGORDANY, ESCALDES-ENGORDANY AD700
● E-mail: lopd@necomplus.com

2. Purposes

¿For what purposes do we process your personal data?

In compliance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, we inform you that, if you are a user, at www.necomplus.com we process the data you provide for the following purposes:

1. We will use your data to answer your queries.
2. Recruitment of personnel to work in Necomplus, S.L.
3. Prevent abuse and fraud in the use of our services (for example, fraudulent activities, denial of service attacks, sending spam, among others).
4. Transfer data to public agencies and authorities, as long as they are required in accordance with legal and regulatory provisions.
5. Cookies. We may process your data for analytical and statistical purposes, i.e. to understand how users interact with our website in order to be able to make improvements to it.

3 Personal data

What type of data do we process?

Depending on the products, services or functionalities that you wish to enjoy at any given time, we will need to process certain data or others. In general, this data will be, depending on the case, the following:

• Your identification data (For example: Your name, surname, language, country from which you interact with us, contact details, etc.).
• Connection, geolocation and navigation data (in case you interact with us from your mobile phone, for example).
• Data about your likes and dislikes (such as language).
• If you use the reporting channel, we will process the informant’s identification and contact details (if the report is not anonymous), as well as the data contained in the communication, which may include data relating to criminal convictions and offences and data relating to administrative offences and penalties.

Please note that when we ask you to fill in your personal data in order to give you access to a functionality or service on the website, we will mark some fields as mandatory, as these are data that we need in order to provide you with the service or give you access to the functionality in question.

Please note that if you choose not to provide us with this information, you may not be able to complete your registration as a user, or you may not be able to take advantage of those services or functionalities.

4. Data retention period

How long will we keep your data?

The length of time we keep your data will depend on the purposes for which we process it:

• Customer Service: We will process your data for as long as necessary to fulfill your request or inquiry. Subsequently, they may be kept for up to 1 year.
• Human Resources: Your CV will be stored for a maximum period of 1 year, unless you are part of the Necomplus, S.L. team, which will be stored until the end of your contract with the organization.
• To prevent abuse and fraud. We will retain the data for the periods legally established in the applicable regulations.
• To transfer data to public bodies and authorities. We will retain the data for the periods of time legally established in the applicable regulations.
• Complaints channel. Personal data relating to information received and internal investigations will only be retained for the period that is necessary and proportionate for the purpose of complying with Law 2/2023 of 20 February. In no case may data be kept for a period of more than ten years. Data undergoing processing may be kept in the information system only for the time necessary to decide whether to initiate an investigation into the facts reported. After three months have elapsed since the receipt of the communication without any investigation having been initiated, the data must be deleted, unless the purpose of the retention is to leave evidence of the operation of the system. Communications that have not been followed up may only be recorded in anonymised form, without the obligation to block them being applicable.
• Cookies. As established in the cookies policy.
• Regardless of the fact that we will process your data for the time strictly necessary to fulfill the corresponding purpose, we will subsequently keep them properly stored and protected for the time that may arise from processing responsibilities, in accordance with the regulations in force at any given time. Once the possible actions have been prescribed in each case, the personal data will be deleted.

5. Legitimation

¿What is the legitimacy for the processing of your data?

We are entitled to process your data for several reasons.

• Customer Service: the legal basis is our interest in dealing with your enquiry and your consent by completing the relevant form.
• Human Resources: the legal basis is pre-contractual, if you sign up for a specific offer, or your consent otherwise.
• Preventing abuse and fraud. The legal basis is compliance with our legal obligations as well as our legitimate interest in preventing fraud.
  Providing data to public bodies and authorities. The legal basis is compliance with legal obligations.
• Complaints channel. Pursuant to Law 2/2023 of 20 February on the protection of persons who report regulatory infringements and the fight against corruption, the processing of personal data shall be deemed lawful under the provisions of Articles 6. 1.c) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, 8 of Organic Law 3/2018 of 5 December and 11 of Organic Law 7/2021 of 26 May when, in accordance with the provisions of Articles 10 and 13 of this law. The processing of special categories of personal data for reasons of an essential public interest may be carried out in accordance with the provisions of Article 9(2)(g) of Regulation (EU) 2016/679.
• Cookies. Your consent to the implementation of cookies.

 

6.Applicable law and jurisdiction

This Legal Notice and its consequences shall be governed in all cases by the Spanish legislation in force at any given time.

7. Addressees

To which recipients will your data be communicated?

In order to fulfill the purposes indicated in this Privacy Policy, it is necessary for us to give access to your personal data to third parties that support us in the services we offer you, such as:

♠ Fraud detection and prevention entities

♠ Technology service providers

♠ Provider of personnel selection processes: Asseco South Eastern Europe S.A., you can consult its privacy policy here.

♠ Whistleblowing channel: The identity of the informant may only be communicated to the judicial authority, the Public Prosecutor’s Office or the competent administrative authority in the context of a criminal, disciplinary or sanctioning investigation. The persons referred to in Law 2/2023 of 20 February may also have access, within the framework of their powers, to the persons referred to in Law 2/2023 of 20 February.
Group companies, for administrative management purposes.

Your personal data may also be transferred to the competent authorities where there is a legal obligation to do so.

International transfers:

Any international transfer of personal data (e.g. in the case of the use of cookies, transfers between group companies, etc.) will be based on your express consent, in the absence of an adequacy decision, adequate safeguards or other legal basis legitimising it.

8. Rights

What are your rights when you provide us with your data and how can you exercise them?

You have the right to obtain information about whether we at Necomplus, S.L. are processing your personal data, so you can exercise your rights of access, rectification, deletion and portability of data and opposition and limitation to their treatment before Necomplus, S.L. Avda. Doctor Jimenez Diaz 19, 1st Floor Box 1. 03005 Alicante or email address lopd@necomplus.com, attaching a copy of your ID or equivalent document.

In particular, regardless of the purpose or legal basis under which we process your data, you have the right to:

♠ Ask us for access to the data we hold about you.

♠ Ask us to rectify the data we already hold about you. Please note, however, that by actively providing us with your personal data in any form, you warrant that it is true and accurate and undertake to notify us of any changes or modifications to it. Remember that, as a general rule, you should only provide us with your own personal data, and not those of third parties.

♠ Ask us to delete your data to the extent that they are no longer necessary for the purpose for which we need to process them as we have informed you above, or where we no longer have the legitimacy to do so.

♠ Ask us to restrict the processing of your data, which means that in certain cases you may ask us to temporarily suspend the processing of the data or to keep it longer than necessary when you may need it. If you have provided us with your consent to the processing of your data for any purpose, you also have the right to withdraw your consent at any time.

Where our legitimacy for processing your data is your consent, as explained in section 54, o a contract also have the right to request portability of your personal data. This means that you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format, so that it can be transmitted to another entity directly, where technically possible. Moreover, where the processing of your data is based on our legitimate interest, you also have the right to object to the processing of your data.

Likewise, and especially if you consider that you have not obtained full satisfaction in the exercise of your rights, you may file a complaint with the national supervisory authority by contacting the Spanish Data Protection Agency, C/ Jorge Juan, 6 – 28001 Madrid.

9. Changes in the Privacy Policy

We may modify the information contained in this Privacy Policy when we deem it appropriate. If we do so, we will notify you through our website (for example, through a banner, a pop-up or a push notification). In any case, we suggest that you review this Privacy Policy from time to time in case there are minor changes or we introduce any interactive improvements, taking advantage of the fact that you will always find it as a permanent point of information on our Web.