Privacy policy
The privacy and confidentiality of user information is important to ELANTA REDES DE ACCESO S.L.U. (hereinafter elanta). We are committed to the privacy and security of user information.
We may update this policy from time to time. So please check back regularly.
This Privacy Policy is intended to help you understand:
Who is responsible for processing your data;
Which regulations apply;
What personal information we collect about you;
How we use, disclose and protect your personal information;
With whom we might communicate your personal data;
How you can update, manage, export and delete your data;
How long will your personal data be kept;
What rights do you have regarding the protection of personal data;
How to contact us to learn more about our privacy practices.
1.- RESPONSIBLE PARTY FOR THE PROCESSING OF PERSONAL DATA
In terms of data protection elanta must be considered a data controller in relation to the personal data collected by it and data processing activities carried out through this website or by other means such as telephone, email, in person, on paper through forms, through legal documents, etc. whose identifying data are the following:
ELANTA REDES DE ACCESO, S.L.U.
CIF: B02944809
Registered in the Mercantile Register of Madrid, Sheet M-731959 Volume 41295 Page 200
Registered office: Paseo Castellana, 259 D, Planta 44, TORRE EMPERADOR, 28046, Madrid. Spain.
Email to protect personal data [email protected]
2.- REGULATIONS
elanta is committed to protecting the privacy of personal data holders by complying with current regulations (EU 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 free movement of such data by which Directive 95/46/EC as well as Organic Law 3/2018 of 5 December on the protection of personal data and guaranteeing digital rights).
3.- INFORMATION WE COLLECT ABOUT YOU
We may collect the following information when you fill out the contact form available on the website www.elanta.com (herein, the Website):
Name and surname.
Email.
The legal basis for this treatment is the express consent that you give us by accepting the Website’s privacy policy.
The purpose of processing your personal data is to process inquiries and send you the information you request.
4.- MINORS
Minors may not use the services offered through the Website without the prior authorisation of their parents, guardians or legal representatives, who will be solely responsible, at their expense, for all actions taken by minors through the Website, including filling out the forms containing the personal data of such minors and, where appropriate, marking the boxes included on them.
5.- SECURITY
elanta is committed to protecting the security of your personal information and your choices regarding its intended use.
The information shared will be stored on a secure server and we will use procedures to protect the personal information we collect from unauthorised access, destruction, use, modification or disclosure.
Although we use commercially reasonable safeguards with respect to your personal information collected and stored (and require our third party service providers to do the same), due to the open nature of the Internet, we cannot guarantee that any personal information stored on our servers or information submitted by a user is safe free from unauthorised access and we disclaim all responsibility for theft or loss, unauthorised access or damage, or interception of data or communications.
6.- COMMUNICATION TO THIRD PARTIES
elanta does not sell or rent your personal information to third parties and will only disclose it to any person or entity if we obtain your prior consent or in accordance with applicable law if such consent is not required for a particular transfer. We will share or provide access to the service providers you use elanta, required for the purposes as described in this Privacy Policy, always complying with the requirements of current legislation.
7.- DURATION
We retain your personal data for as long as necessary to fulfil the purposes for which they were collected, provided that you do not request their deletion or object to the processing of your data.
In any case, we will keep your data for as long as we are obliged to fulfil a legal obligation.
8.- EXERCISE OF RIGHTS
As the owner of personal data, you can exercise the following rights at any time:
Right to withdraw consent given;
Right of access about the information we process about you;
Right to rectification your data if it turns out to be incorrect or incomplete;
Right to deletion if your data is no longer necessary for the purposes for which it was collected, or for other reasons;
Right to object to treatment your data in certain circumstances, for example for direct marketing, including profiling;
Right to restrict treatment: in the cases provided for by law. Likewise, if you dispute the accuracy of the personal data, we may limit the processing, only for the period that allows us to verify the accuracy; or if you object to treatment while we are checking whether the objection is appropriate.
Right to data portability: You have the right to move, copy or transfer the data you have provided to us from our database to another in a structured, commonly used and machine-readable format. The exercise of this right is only possible in relation to the data you have provided if the processing is based on the performance of a contract or on your consent and the processing is carried out using automated procedures.
Right to lodge a complaint with the Spanish Data Protection Agency if you consider that the treatment does not comply with current regulations.
To do this, you must send a written request in which you must indicate the right you are exercising, your first and last name, your address for notification purposes and a copy of your ID card or other valid document proving your identity addressed to:
ELANTA REDES DE ACCESO, S.L.U. (ELANTA)
Address: Paseo Castellana, 259D, Planta 44, TORRE EMPERADOR, 28046, Madrid. España.
Email: [email protected]
In particular, we inform you of the right to file a complaint with the Spanish Data Protection Agency (www.aepd.es) if you consider that the treatment does not comply with current regulations.
9.- CHANGES TO THIS POLICY
We are and will continue to evaluate this Privacy Policy based on new technologies and services, or changes in legislation and will make changes to this Privacy Policy as necessary. If there are any significant changes, we will notify you by email.
10. WHISTLEBLOWING AND ANTI-HARASSMENT CHANNEL PRIVACY POLICY
10.1. DATA CONTROLLER
For data protection purposes, elanta must be considered the Data Controller in relation to the personal data it collects and the data processing activities it carries out through this website or through any other means such as telephone, email, in-person, paper forms, legal documents, etc. The identifying information of the company is as follows:
— Company Name: ELANTA REDES DE ACCESO S.L.U.
— Tax ID (CIF): B02944809
— Postal Address: Paseo Castellana, 259 D, Floor 44, TORRE EMPERADOR, 28046, Madrid, Spain
— Email Address: [email protected]
elanta is committed to maintaining strict privacy, security, and data retention practices, as outlined in our Compliance policies and procedures. These standards will also apply to all personal data related to reports made under this Policy.
The processing of personal data will be subject to the provisions of the European General Data Protection Regulation (GDPR) 2016/679 of April 27, 2016, and the Spanish Organic Law 3/2018 of December 5 on the Protection of Personal Data and Guarantee of Digital Rights, and its implementing regulations.
elanta will maintain a record of all reports received. These records and the personal data they contain will be kept confidential. Records will not be retained longer than necessary and, in any case, only for as long as required to meet applicable legal obligations at any given time.
Specifically, elanta will retain the whistleblower’s personal data only for the time strictly necessary to determine whether it is appropriate to initiate an investigation into the reported facts or behavior. Once this decision is made, the data will be removed from the system record, although they may continue to be processed outside of the system for as long as needed to investigate the facts. Once the investigation is completed and any necessary actions have been taken, the data from reports that were followed up on will be securely blocked to comply with legal obligations as applicable in each case.
In any event, personal data will be deleted within a maximum period of six (6) months from their submission, unless they must be retained for a longer period to fulfill legal or corporate obligations, such as providing evidence of the operation of the criminal compliance model. Data may continue to be processed outside of the Ethics Channel if the investigation is still ongoing, for as long as necessary until it is concluded.
• Personal data subject to processing:
During the handling of reports made under this Policy, elanta collects the following personal data and information provided when submitting a report and throughout its investigation:
• Name and contact details of the whistleblower (unless reported anonymously);
• Name and other personal data of individuals mentioned in the report (alleged offender, possible witnesses, and others), if such information is provided (i.e., job descriptions, contact details, and roles in relation to the reported facts);
• Description of the alleged wrongdoing and the circumstances of the incident(s).
10.2. PURPOSE OF PROCESSING
At all times, only personal data that are strictly necessary will be processed to manage, handle, and investigate reports relating to irregularities or acts contrary to ethics, the law, or elanta’s corporate policies, and to carry out any necessary actions related to the investigation, including, where appropriate, disciplinary or legal actions.
Personal data will not be used for any purpose other than that stated above.
10.3. LEGAL BASIS FOR PROCESSING
The processing of personal data within the ethics channel is based on the existence of a public interest, as established in Article 6.1(e) of the General Data Protection Regulation, for the purpose of detecting and preventing complaints and thereby preventing harm and liability risks for elanta. This is also defined in Article 24 of Organic Law 3/2018 of December 5 on the Protection of Personal Data and Guarantee of Digital Rights, which allows for the creation and maintenance of internal reporting systems and the investigation of potential irregularities or acts contrary to ethics, the law, or corporate policies.
Additionally, processing may also be based on the fulfillment of a legal obligation or on elanta’s legitimate interest.
Therefore, the processing of the whistleblower’s personal data is strictly necessary to manage the report and fulfill the stated purposes and legal obligations. Under no circumstances will elanta make automated decisions based on the submitted data.
10.4. RECIPIENTS OF PERSONAL DATA
Personal data collected in connection with a report submitted through the whistleblowing channels may be processed or disclosed to the following parties when necessary:
— elanta’s legal department responsible for receiving and processing reports.
— The Supervisory Body and the Board of Directors or authorized representatives of elanta, if the nature or scope of the reported facts requires their involvement.
— Investigators, advisors, or external consultants hired to support elanta in evaluating the report, investigating the matter, or providing advice.
— Police and/or other regulatory or law enforcement authorities.
10.5. WHISTLEBLOWER RIGHTS IN RELATION TO DATA PROTECTION
As an informant, the reporting individual may exercise their rights at any time under applicable legislation to access their personal data. If they believe the data is incorrect or incomplete, they may request its correction. They may also request the deletion of data if it is no longer necessary, except where there is a legal obligation to retain it.
Additionally, they may request the restriction of the processing of their data, object to its processing, or request data portability, and they have the right to withdraw consent at any time. When submitting a report, the whistleblower will be informed of how to exercise these rights.
If they deem it appropriate, they may also file a complaint with the relevant data protection authority.