Vinces Consulting, S.L., in compliance with personal data protection regulations, informs the user of this website (hereinafter, the “User”), contained on the page www.vincesconsulting.com (hereinafter, the “Website”), of the following conditions, which will govern the processing of your personal data in the context of your use of and interaction with the Website, as well as the processing of your data in terms of the contact you may establish with Vinces Consulting.
Responsible of the processing of personal data
Vinces Consulting, S.L. (hereinafter, “Vinces“), with registered office at Calle de Fortuny 45, 28010, Madrid (Spain), and with Tax Identification Number (NIF) B-85722106.
Vinces has an area dedicated to the attention and management of all questions related to data protection. For this purpose, the User may contact this area at firstname.lastname@example.org.
Purpose of data processing and basis of legitimisation
The User’s personal data will be processed by Vinces for the following purposes and on the following legitimate bases:
Purpose 1: attention of communications, requests for information and solving queries.
- Data processed for this purpose: identification and contact data communicated through the means provided by Vinces, such as the form on the Website, by e-mail or by telephone. Specifically, and among other data that may be communicated depending on the specific query or communication that is sent, the processing of the name, surname, e-mail address, telephone number, professional position and company or entity in which the User works is envisaged.
- Description of the purpose: to deal with the query and provide the information requested by the user.
- Basis of legitimacy: consent of the User through the sending of the form, understanding that the sending of the query constitutes a clear affirmative action for the processing of the data with the aim of resolving it.
Purpose 2: Client relationship management.
- Data processed for this purpose: identification, contact and, where appropriate, financial, training and academic data, communicated through the means provided by Vinces, such as the form on the Website, by e-mail, by telephone, in the contract for the provision of services or during the development of the relationship with Vinces.Specifically, and among other data that may be communicated, the processing of the name, surname, e-mail address, telephone number, professional position and company or entity in which the holder of the processed data works is foreseen.
- Description of the purpose: to manage, within the framework of the provision of its services, all aspects that may arise from the legal relationship entered into with Vinces.
- Basis of legitimacy: execution of the contractual relationship.
Purpose 3: data analysis by means of cookies.
- Data processed for this purpose: depending on the case, identification, contact and browsing data may be processed. For example: browsing habits (browsing patterns, functionalities and services most frequently requested, preferences, etc.) or requested functionalities and services, preferences, etc.) or browsing identifiers (browsing device or IP address).
- Description of the purpose: to analyse the User’s browsing on the Website in order to know the browsing patterns and thus improve the Website in those that are detected to be negative for the user experience and use of the Website.
- Basis of legitimacy: consent of the interested party, granted in accordance with the provisions of our cookies policy.
Purpose 4: sending Vinces-related commercial communications
- Data processed for this purpose: identification and contact data, such as name, surname and e-mail address.
- Description of the purpose: to send commercial communications related to the activity of Vinces.
- Basis of legitimacy: consent of the User (recipient of the communications). The User, at any time, may withdraw the consent given by writing to email@example.com.
Purpose 5: management of the Website’s private area
- Data processed for this purpose: identification, contact and professional data, such as name, surname, e-mail address, professional position and company or entity in which the User works.
- Description of the purpose: to grant and manage access to the reserved area of the Website.
- Basis of legitimacy: execution of the contractual relationship and provision of the requested service (access to the reserved area).
Purpose 6: Talent recruitment.
- Data processed for this purpose: identification, contact and professional data, such as name, surname, email address, academic background and previous work experience.
- Description of the purpose: to manage the job applications that may be published at any time, as well as to manage the database of CVs received by electronic means, to study the CVs and assess new recruits to the Vinces team.
- Basis of legitimisation: establishment of pre-contractual measures at the request of the interested party, with the intention of concluding a contract, within the framework of the selection processes in which the sender of the curriculum vitae participates.
Processing of professional location data
In addition to the above purposes, which are more closely related to the Users of the Website, Vinces also processes personal data relating to natural persons who have a professional relationship with relevant entities and bodies in the political, regulatory and social spheres, such as ministries, political parties, public bodies and administrations, parliaments, professional associations, consumer associations or foundations.
The data processed are identification, contact and professional data, such as, for example, name and surname, e-mail address and contact telephone number, profession, professional career, and current professional position held.
The purpose of the above data processing is to be able to professionally locate the data subjects (public, regulatory and social representatives), in order to contact them on professional terms within the framework of the strategic consultancy work carried out by Vinces.
The processing is based on Vinces’ legitimate interest in identifying, at all times, significant representatives of the political, regulatory and social environments, in order to be able to carry out the aforementioned strategic consultancy work. Data subjects affected by this processing may (i) obtain further information about the processing of their data and (ii) exercise their right to object to the processing by contacting firstname.lastname@example.org.
Time limits for the storage of personal data
The personal data processed will be kept for the time necessary to fulfil the stated purpose in each case. By way of reference, the following retention periods may be observed:
- Resolving queries, requesting information or dealing with incidents: the data will be kept for the time required to resolve the doubt or question raised with Vinces, as well as for the time required to manage any incidents that may arise.
- Sending of commercial communications: the data will be kept as long as the circumstance enabling the processing is maintained. That is: the consent of the User.
- Retention of CVs: CVs received may be kept for a period of 1 year after their last update, in anticipation of their usefulness in filling future vacancies in the Vinces team.
The user can contact email@example.com for further information on the applicable retention periods.
At the end of the foreseen storage period (depending on the purpose), the personal data may be kept, properly blocked, during the periods of prescription of the legal actions and responsibilities that may arise, in each case, from the specific processing activity carried out, after which they will be completely deleted.
Recipients of personal data
Personal data, according to the above-mentioned purposes, may be transferred:
- To Vinces suppliers, who will carry out their functions in their role as data processors. The User (or any other interested third party) may request information about the persons in charge that Vinces has at any time for the development of its activity.
- To Judges, Courts or Public Administrations to whom Vinces may have to communicate the personal data of any User. No international transfer of Users’ personal data is planned.
However, in the case of any international transfer, it shall be carried out in accordance with the criteria and requirements demanded by the regulations in force, by means of the adoption of appropriate legal guarantees, which may consist of the formalisation with the recipient of the data of (i) Standard Contractual Clauses approved by the European Commission to legitimise the international transfer of data to third countries or (ii) another valid legal instrument that guarantees an adequate level of protection equivalent to that of the European Economic Area.
The User will be able to exercise the rights of access, rectification or suppression, limitation of processing, opposition, portability, to oppose automated individual decisions and to withdraw the consent granted to Vinces, by writing to the e-mail address firstname.lastname@example.org or to the registered office indicated above.
In addition, Users are informed of their right to submit a complaint to the Spanish Data Protection Agency if they believe that their rights have been violated.
Policy version: june 2021