Processing of personal data

At JAKINCODE, S.L., we care about the personal data we process and about exact compliance with current regulations on personal data protection, including Regulation (EU) 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 on the free movement of such data and repealing Directive 95/46/EC and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights. 

In accordance with the above, we hereby inform you of the following issues regarding the processing of personal data that we carry out at JAKINCODE, S.L.: 

Who is responsible for the processing of your personal data? 

Identity: JAKINCODE, S.L.
Tax ID No. (NIF): B01528538
Postal address: Alava Technology Park, C/ Albert Einstein 44, Edif. E6 – Ofic.112, 01510 Miñano, Vitoria-Gasteiz (Araba/Álava)
Phone: 945 19 84 26
Email: dpo@jakincode.com

Principles relating to processing 

The principles required by Regulation (EU) 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 on the free movement of such data and repealing Directive 95/46/EC (hereinafter, GDPR) are observed during the processing of personal data carried out therein: 

• Principle of lawfulness, fairness and transparency: the data we collect is processed lawfully, fairly and transparently, with the prior consent of the data subjects, where necessary, or, where appropriate, for the performance of a contract to which the data subject is party or for the implementation at the request of the latter of pre-contractual measures or, if the processing is necessary for compliance with an applicable legal obligation or for the fulfilment of legitimate interests pursued by the controller or by a third party, provided that such interests are not overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data, in particular where the data subject is a child. 
• Principle of purpose limitation: the personal data we process is used for the purposes mentioned in the section “For which purposes do we use your personal data”.

• Principle of data minimisation: in accordance with this principle, the only personal data we collect from users is that which is strictly necessary to manage the contractual relationship or to be able to deal with the queries and/or requests for information that we get from them. 
• Principle of accuracy: the personal data we collect will be kept accurate and, if necessary, updated. To this end, in the event of any change in personal data, the user must notify us so that we can carry out the appropriate update. 
• Principle of limitation of the storage period: the personal data that we process will be kept for the periods mentioned in the section “How long will we keep your personal data?”. 
• Principle of integrity and confidentiality: to observe this principle, personal data will be processed in a way that guarantees ensures appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, while using appropriate technical and organisational measures. 

For which purposes do we use your personal data (whether or not you are a user of the website)?

Customer data: for the proper maintenance, development, compliance and control of the contractual relationship and the provision of the services requested. 
We will also use your identification and contact details to carry out satisfaction surveys and to send, by electronic means or otherwise, technical, operational and/or commercial information, news and commercial information on our company’s offers, activities, products and services. 

Supplier data: for the proper maintenance, development, compliance and control of the contractual relationship with our suppliers and the services they provide us. 

Personnel data: for maintenance, development, compliance and control of the contractual relationship with our employees, as well as compliance with current Labour, Social Security and Occupational Risk Prevention regulations that may be applicable. 

Candidate data: to manage the participation of interested parties in the personnel selection processes carried out by the company. 

Data collected through the contact form: to manage and respond to queries or requests for information made by interested parties. 

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

Candidates’ data: The basis for the processing of their personal data is that it is necessary for the performance of the contract to which they are a party. 

With regard to carrying out satisfaction surveys and sending commercial information, the basis for the processing of your personal data is the satisfaction of legitimate interests pursued by JAKINCODE, S.L., in accordance with Article 6.1. f) of the GDPR, based on the provisions of Report 195/2017 of the AEPD (Spanish Data Protection Agency). This will be without prejudice to the possibility that you have of opposing the sending of this commercial information. 

Suppliers’ data: The basis for the processing of their personal data is that it is necessary for the performance of the contract to which they are a party. 

Personnel data: the basis for the processing of their personal data is that it is necessary for the performance of the contract to which they are a party. 

Candidates’ data: The basis for the processing of their personal data is the consent they give when they provide us with their curriculum vitae to participate in the personnel selection processes that we carry out. 

Data collected through the contact form: The basis for the processing of the personal data provided by the interested parties when filling in the form is the consent given when contacting us through it and, therefore, the need for such processing in order to attend to and respond to the query or request for information that you make to us. 

How have we obtained your personal data? 

All the personal data that we process at JAKINCODE, S.L. is provided to us by the interested parties themselves or their legal representatives. 

The personal data that we collect on this website has been collected through the form provided or through the e-mail address provided to contact us.

To which recipients will your personal data be disclosed?

The personal data of customers, suppliers and employees will be communicated, where appropriate, to the tax authorities for compliance with legal and tax obligations, as well as to the financial institution(s) through which JAKINCODE, S.L. manages the collections and payments. 

As regards other processing, the data will not be communicated to third parties, unless it is necessary to comply with legal obligations. 

Likewise, for certain other matters we use third-party services, which act as data processors, with whom we have signed the respective data processing contract in accordance with the provisions of Article 28.3 of the GDPR. 

International data transfers

For some information management purposes, we use the services of Google, a company that acts as a data processor and which, despite being outside the European Union and the European Economic Area, is covered by the EU-US Privacy Shield, as stated in the following link: Participant Search (dataprivacyframework.gov)

Google privacy policy: https://policies.google.com/privacy?hl=es&gl=es 

Likewise, in order to manage in a more efficient, dynamic and operational way and to be able to keep better control of the informative communications that we send by e-mail, we use MailChimp, a platform developed by The Rocket Science Group LLC, an organisation that is certified within the framework of the EU-US Privacy Shield Policy. Information available in this regard: Participant Search (dataprivacyframework.gov)

The Rocket Science Group LLC Privacy Policy: https://mailchimp.com/legal/privacy/ 

In this regard, we inform you that using this platform involves the installation by the provider of the aforementioned service in these mailings of devices for monitoring the recipients’ activity, in order to control the opening of e-mails and the clicking of links included in the e-mails, and to be able to draw up campaign monitoring reports with the information collected.

How long will we keep your personal data?

Client, supplier and employee data: Personal data will be kept for the duration of the contractual relationship and, once it has ended, for as long as necessary to comply with legal obligations. 

With regard to the sending of commercial information to customers, their personal identification and contact data will be kept until they express their opposition or revoke their consent for this purpose. 

Candidates’ data: Candidates’ personal data will be kept for a maximum period of two years. 

Data collected through the contact form: The personal data provided by users when filling in the form will only be kept during the management of the queries or requests they make to us so that, once they have been processed, they will be deleted. Data from users of our profiles on social networks: the retention periods of the personal data of our followers on social networks depend on the policies of each social network, although we will only process them until they stop following us.

What are your rights when you provide us with your personal data? 

• Right to request access to your personal data: In order to know and check the lawfulness of the processing, you may ask us at any time to confirm whether JAKINCODE, S.L. is processing your personal data, and, if so, we will inform you, among other things, about what data we are processing, its purpose, the origin of the data, the expected period of data retention and, where appropriate, the recipients or categories of recipients. 
• Right to request rectification: You may request us to rectify personal data that is inaccurate or to supplement personal data that is incomplete, including via an additional statement. In this case, you must specify in your request which data you are referring to and the correction to be made and, if necessary, provide us with supporting documentation of the inaccuracy or incompleteness of the data being processed. 
• Right to request deletion (“right to be forgotten”): You may request that your personal data be deleted and stop being processed if it is no longer necessary for the purposes for which it was collected or otherwise processed in another way, you withdraw your consent, it has been unlawfully processed or it must be deleted to comply with a legal obligation. 

• Right to request the limitation of the processing of your personal data: In this case, JAKINCODE, S.L. will only keep your personal data for drawing up, exercising or defending claims, or for the protection of the rights of another natural or legal person or for reasons of substantial public interest. 
• Right to the portability of your personal data: You can ask us to provide your personal data, to you or to another controller you specify, in a structured, commonly used and machine-readable format. 
• Right to object to processing: JAKINCODE, S.L. will stop processing your personal data in the manner you specify, unless we have to continue processing it for compelling legitimate reasons or for drawing up, exercising or defending possible claims.

How to exercise your data protection rights: To exercise your rights you must send us a written request addressed to JAKINCODE, S.L. at Calle Adriano VI, no. 20-4º Office 6 P.C. 01008 Vitoria (Alava) or by sending an e-mail to dpo@jakincode.com, attaching in any case a photocopy of your ID. 

JAKINCODE, S.L. will respond to all requests within the terms and conditions required by current regulations on the protection of personal data. 

How to file a claim with the Spanish Data Protection Agency: If you consider that we have not properly processed your personal data or that we have not duly addressed the exercise of your data protection rights, you can file a claim with the Spanish Data Protection Agency, either through its electronic headquarters or at its address, at Calle Jorge Juan, no. 6, P.C. 28001 Madrid. More information on data protection rights and claims filed with the Supervisory Authority at www.aepd.es.

Security

In accordance with the provisions of Article 32 of the GDPR, JAKINCODE, S.L. has adopted the appropriate technical and organisational measures to ensure a security level according to the risk. 

In order to assess the appropriate security level, particular account has been taken of the risks presented by data processing, in particular as a result of accidental or unlawful destruction, loss or alteration of personal data submitted, stored or otherwise processed, or unauthorised communication or access to such data.

Duty of secrecy

JAKINCODE, S.L. has adopted measures to ensure that any person acting under their respective authority who has access to the personal data provided to us by users may only process them on the company’s instructions and must also keep the corresponding professional secrecy about them, which shall last indefinitely. 

To this end, our employees have signed a document of confidentiality and duty of secrecy regarding the information and personal data that they process as part of their work relationship with the company. 

Use of the website by minors

We kindly ask users to read the policies on website use by minors that we have published in the “Legal Notice” of our website. 

Cookies

Cookies are small text files that are stored on the hard drive or in the memory of the computer that accesses or visits the pages of certain websites, so that the user’s preferences can be known on reconnecting. Cookies stored on the user’s hard drive cannot read the data contained therein, access personal information or read cookies created by other providers. See information on the cookies used on this website in the “Cookie Policy” section.