Privacy policy

IMPORTANCE OF PRIVACY

The protection of personal data of users and clients is paramount, and therefore, we wish to explain and facilitate in a transparent manner how we collect, protect, use and share this data in the development of our activity.

Personal data should be understood as information about an identified or identifiable natural person, which we collect through some of the established channels, such as:

Data collection forms inserted in our website, by telephone or in person when filling out any of our forms, among others.

Regardless of the channel chosen, we recommend that you carefully read the information provided on privacy, and if you have any doubts about any of the sections collected, please contact us by sending an e-mail request to: dpd@electronica-submarina.com

It is very important that you understand:

WHO COLLECTS YOUR PERSONAL DATA AND IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?

Identification and contact details of the data controller:

Sociedad Anónima de Electrónica Submarina S.M.E., (SAES) is responsible for the processing of your personal data.

- - Registrar data: Mercantile Register of Murcia: Volume 509, Folio 148, Section 3a, Page 9005
  - NIF: A79144267
  - Company address: Ctra. Algameca s/n, 30205, Cartagena (Murcia, Spain)
  - Contact of the Data Protection Delegate: dpd@electronica-submarina.com

WHICH PERSONAL DATA DO WE COLLECT?

Depending on the type of web form used or application employed, we will collect certain personal or technical information.

		TECHNICAL DATA OF WEB USERS	a) Device information. (IP address, unique identifier, operating system, version and if applicable, browser.) b) Cookies and similar technologies. c) Date, time and duration of the connection or operation carried out, type of connection.
CANDIDATES FOR EMPLOYMENT		Data of an identifying nature. Data related to personal characteristics of candidate personnel. Academic and professional data. Data related to employment details.
CANDIDATES FOR SELECTIVE PROCESSES (PUBLIC)		Data of an identifying nature. Data related to personal characteristics of the candidate personnel. Academic and professional data. Data related to employment details.
COMMON (to deal with data protection requests)		Data of an identifying nature. Contact data.
COMMON (manage and process claims, complaints and queries )		Identifying data. Contact data.
Complaints Channel		Identifying data. Contact data. Employment detail data. Transaction data. Economic-financial data.
SOCIAL NETWORKS		Identifying data. Contact data.
VIDEOVIGILANCE	Identifying data
WIFI FOR. VISITORS	Identifying data

HOW DO WE GET YOUR PERSONAL DATA?

From the information you provide directly to us through the data collection channels enabled, such as:

- - Forms inserted on the website and traditional media.
  - Social networks.
  - Employment.
  - Video surveillance.
  - Wifi for visitors.

From information provided by third parties:

- - Legal representative or authorized person, in the case of minors, incapable or legal representatives or joint accounts.
  - From third parties whose cookies are applied on the web.

WHY DO WE PROCESS PERSONAL DATA?

Identification of purposes and applicable legal bases.

We inform you that all data processed by Sociedad Anónima de Electrónica Submarina S.M.E., (SAES) are necessary for the purposes described in this

Privacy Policy and failure to provide them would make it impossible to properly manage the existing relationship with you.

The different purposes for which your personal data are processed and the bases that legitimize the processing are described below:

PURPOSES		PURPOSES		APPLICABLE LEGAL BASIS
USERS OF THE WEB		Use of data obtained from non-necessary cookies and other technologies when accessing our website.	Consent of users.
	To deal with doubts and queries processed through the established customer service channels and provide requested information. Managing and transferring the suggestion or complaint raised.	Legitimate interest, or execution of a contract in the case of being a customer.
	Analyzing user behavior on the website to prevent and detect illicit activities such as, attacks against the security of the same that affect the confidentiality, integrity of the personal data of other users and availability of the website.	Legitimate interest.
CANDIDATES FOR EMPLOYMENT		Evaluating the possibility of recruitment. Reception and storage of resumes.		Execution of pre-contractual measures.
CANDIDATES IN SELECTIVE PROCESSES (PUBLIC)		Management of applications during selective processes. Communications with participants.		Fulfillment of a legal obligation.
COMMON		To deal with data protection requests, such as exercising rights. To notify, if necessary, a security breach.	Fulfillment of a legal obligation.
COMMON	To attend to, manage and process claims, complaints and queries received through the customer service and/or the rest of the channels enabled by the Data Controller for this purpose.	Legitimate interest.
CLAIMS CHANNEL	To manage and prevent regulatory non-compliance (compliance)	Compliance with a legal obligation.
SOCIAL NETWORKS	To register and process requests and queries received through the RRSS.	Consent of the data subject.
VIDEOVIGILANCE		Video surveillance to guarantee the security of persons, goods and facilities. Video surveillance for the purpose of communicating images to Judges or Courts or Security Forces and Corps.	Fulfillment of a legal obligation. Legitimate interest. Fulfillment of a mission carried out in the public interest.
WIFI FOR VISITORS		Control/registration of access to the wifi system for visitors.	Legitimate interest.

INFORMATION ON APPLICABLE LEGAL BASIS AND OBLIGATION TO PROVIDE DATA.

Information on applicable legal basis.

In the event that the applicable legal basis proves to be, legitimate interest, you may object to any of the processing, based on the same, by contacting the Data Protection Officer at: dpd@electronica-submarina.com and explaining the reason for such opposition. In such a case, the Data Controller will weigh whether the aforementioned interest prevails over the rights of the data subjects.

With respect to those processing operations based on the consent provided, the lack of authorization will not affect the maintenance or fulfillment of the contractual relationship with Sociedad Anónima de Electrónica Submarina S.M.E., (SAES). Furthermore, once the authorization has been given, you may withdraw it at any time without affecting the processing previously carried out. In any case, your consent will remain in force as long as you do not withdraw it.

Obligation to provide data.

In some cases, it is mandatory to collect certain personal information before handling your request or providing one of our services either because such information is the minimum necessary to fulfill your request or because we are legally obliged to collect it.

However, Sociedad Anónima de Electrónica Submarina S.M.E., (SAES) undertakes to collect only those data necessary for the purpose pursued.

You should know that, in these cases, if the required information is not provided, it may generate delays in the provision of the requested services or even lead to the impossibility of providing them. Mandatory changes will normally be marked with an asterisk (*).

HOW WE SHARE INFORMATION WITH THIRD PARTIES?

To comply with applicable legal obligations, your data may be transferred to the following recipients:

- - Spanish Data Protection Agency.
  - Computer Security Incident Response Teams (CSIRT) and Computer Emergency Response Teams (CERT).
  - State Security Forces and Corps.
  - Ministry of Public Prosecution, Judges and Courts.
  - Finally, in certain cases, some of our suppliers may process your personal data in the name and on behalf of the Data Controller as necessary for the development of the specific activity. Specifically, some of these suppliers are:
    - Providers of IT services such as servers, cloud platforms.
    - Events or marketing activities, research.
    - Administrators, investors, managers.
    - Design, maintenance of tools and applications.
    - Specialized mailing services.
    - Destruction of information.

As a general rule, no data transfers are made to third parties located or whose servers are located outside the European Economic Area. However, in those cases where you accept the use of third party cookies, your information may be shared with third parties located outside the European Economic Area. For more information, please see our cookie policy.

For how long will we store your data?

As a general rule, your data will be deleted when they are no longer necessary to fulfill the purpose for which they were collected.

In the event that the processing is only based on your consent, your data will be processed until your consent is withdrawn.

Without prejudice to the foregoing, the privacy regulations provide for the possibility of retaining certain data for longer than necessary for the achievement of the purpose originally pursued, in the following cases:

- - Fulfillment of a legal obligation pursuant to Article 17.3.b of the RGPD.
  - Purposes of archiving in the public interest, scientific and historical research, statistical purposes in accordance with Article 17.3.c and 89 of the RGPD.
  - Execution or defense of claims in accordance with Article 17.3.e of the RGPD.

In accordance with the provisions of the LOPDGDD, when the rectification or deletion of the data, based on the principle of proactive responsibility, we may continue to keep your data blocked (i.e. with restricted access) prior to the final physical or digital erasure, during the limitation periods established in the applicable regulations and for the sole purpose of addressing or demanding possible liabilities arising from the treatment.

Access to the data and consequently, the availability of the same is limited only to judges and courts, the Public Prosecutor’s Office or Public Administrations.

Final deletion of your data:

Your data will be definitively destroyed when the retention periods imposed by the rules governing our activity and the statute of limitations for administrative or judicial actions arising from the relations established between you and us have elapsed.

In the case of the use of cookies, your data will be retained in accordance with the provisions of the said policy.

PROFILING AND AUTOMATED DECISION MAKING.

Through the data collected through the website, the data controller does not make automated decisions or profiles.

WHICH ARE YOUR PRIVACY RIGHTS AND HOW CAN YOU EXERCISE THEM?

RIGHTS		Access		You may consult your data included in the databases of the contracting body.
	Rectification		You may modify your personal data when they are inaccurate.
	Deletion		You may request the deletion of your personal data.
	Opposition	You may request that your personal data not be processed.
	Portability		You may receive, in electronic format, the personal data provided to the contracting body, as well as transmit them to another third party.
	Limitation	You may request the limitation of the processing of your data: – when the contestability of the accuracy of your data is ascertained, – when the processing is unlawful and you object to the erasure of your data, – when the contracting body does not need to process your data, but you need it for the exercise or defense of claims, – when you have objected to the processing of your data for the performance of a task in the public interest or for the satisfaction of a legitimate interest, while verifying whether the legitimate grounds for the processing outweigh yours.
	If processing is carried out as a result of an authorization or consent previously given, you may withdraw your authorization, and where appropriate, where appropriate, not to be subject to a decision based solely on automated processing, including profiling and where appropriate, to obtain human intervention by the controller, to express your point of view and to challenge the decision. How can you exercise your rights? – We have forms for the exercise of your rights; you can request them to us via email or if you prefer, you can use those developed by the Spanish Data Protection Agency (https://www.aepd.es) or the competent authority. – These forms must be signed electronically or be accompanied by a copy of your ID card or valid official document that accredits you. The forms can be sent: – By post to the address: Ctra. Algameca s/n, 30205, Cartagena (Murcia, Spain) – By e-mail: dpd@electronica-submarina.com – At our headquarters. Complaints to the supervisory authority. In the event that you consider that your data protection rights have been violated, or your request has not been properly addressed, you can file a complaint with the Control Authority (Spanish Data Protection Agency) https://www.aepd.es/es. – Postal address: C/ Jorge Juan, 6. 28001 – Madrid. – Tel. 91 266 35 17. – Electronic address: https://sedeagpd.gob.es/sede-electronica-web/.

REVIEW AND AMENDMENT OF THE POLICY.

We will review this Privacy Policy whenever it is necessary to keep you properly informed, for example, when new rules or criteria are published or new processing operations are carried out. We will notify you through the usual communication channels whenever there are material or important changes to this Privacy Policy. However, we recommend that you visit and read our policy whenever you access the website.

FURTHER INFORMATION.

For more information about our Privacy Policy and how we use your personal data you can contact us through any of the means mentioned throughout this policy.

Last version date: 13th February 2024