In case of discrepancy, the Spanish version prevails.

GRUPO ALINVENTOR DESARROLLO ESTRATEGICO, S.L. is an organisation that collects personal data through the various means at its disposal, which entails significant responsibility for the design and organisation of procedures so that they are aligned with legal compliance in data protection. For this reason, GRUPO ALINVENTOR DESARROLLO ESTRATEGICO, S.L. will adopt all necessary security measures to ensure the protection of the data collected.

In exercising these responsibilities, and in order to establish the general principles that must govern the processing of personal data in the organisation, GRUPO ALINVENTOR DESARROLLO ESTRATEGICO, S.L. approves this Personal Data Protection Policy, which it notifies and makes available to all its stakeholders, while also observing the following legislation:

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 (GDPR).
Spanish Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights (LOPD-GDD).
Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE).

Scope

This Personal Data Protection Policy applies to GRUPO ALINVENTOR DESARROLLO ESTRATEGICO, S.L., to its administrative, management and staff bodies, as well as to all persons who deal with the organisation, expressly including service providers with access to data («data processors»).

The controller of the personal data collected in the organisation is GRUPO ALINVENTOR DESARROLLO ESTRATEGICO, S.L., with Tax ID (NIF) B54963780, whose representative is Jesús Ruiz Planelles (hereinafter, the «data controller»).

Data controller details

Identity: GRUPO ALINVENTOR DESARROLLO ESTRATEGICO, S.L.
Address: AV Salamanca, 14, 1, Alicante/Alacant, Alicante, 03005
Contact phone: 965 349 770
Email: info@mindden.com

Purposes of the processing of personal data

Data processing	Purpose of the processing	Retention period
Clients	Client management, accounting, tax and administrative	Client management: 5 years. Accounting: 6 years. Tax: 4 years. Administrative: 5 years.
Suppliers	Client management, accounting, tax and administrative	Client management: 5 years. Accounting, tax and administrative: 6 years (accounting and commercial records) and 4 years (tax records).
Human resources	Client management, accounting, tax and administrative, payroll management, occupational risk prevention, human resources	Administrative: 4 years. Payroll management: 4 years. Occupational risk prevention: 40 years (in medical records in the event of exposure to carcinogenic agents). Human resources: 4 years.
Web form	Client management, accounting, tax and administrative	Client management: for the duration of the contractual relationship and, subsequently, during the limitation periods for applicable legal actions. Accounting, tax and administrative: 4 years.
Video surveillance	Security and building access control, video surveillance	Security and building access control: maximum 1 month. Video surveillance: maximum 1 month.
Ethics channel	Ethics channel / whistleblowing	Retained for 3 months (blocked) and, if an investigation or proceeding arises, until its conclusion and during the limitation periods for any possible legal actions.
CVs	Client management, accounting, tax and administrative	Client management: 5 years. Accounting: 6 years. Tax: 4 years. Administrative: 5 years.

Legal basis for the processing of personal data

Data processing	Legal basis
Clients	Performance of a services contract
Suppliers	Performance of a services contract
Human resources	Performance of an employment contract
Web form	Legitimate interest / consent of the data subject
Video surveillance	Public interest / video surveillance
Ethics channel	Public interest / legal obligation
CVs	Legitimate interest / consent of the data subject

Recipients of your personal data

Data processing	Anticipated disclosures	International transfers
Clients	Public authorities with competence in the matter; entities dedicated to the fulfilment or non-fulfilment of monetary obligations	No
Suppliers	Public authorities with competence in the matter; entities dedicated to the fulfilment or non-fulfilment of monetary obligations	No
Human resources	Public authorities with competence in the matter	No
Web form	Public authorities with competence in the matter	No
Video surveillance	Public authorities with competence in the matter	No
Ethics channel	Public authorities with competence in the matter	No
CVs	Public authorities with competence in the matter	No

Your rights and the means available to you

Any person has the right to obtain confirmation as to whether GRUPO ALINVENTOR DESARROLLO ESTRATEGICO, S.L. is processing personal data concerning them.

Data subjects have the right to access their personal data, as well as to request the rectification of inaccurate data or, where appropriate, request its erasure when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

In certain circumstances, data subjects may request the restriction of the processing of their data, in which case we will retain it only for the exercise or defence of claims, as well as to comply with the legally established retention periods.

Data subjects may also object to the processing of their personal data. Accordingly, GRUPO ALINVENTOR DESARROLLO ESTRATEGICO, S.L. will cease processing their data, except for compelling legitimate grounds, or in the exercise of possible claims.

Likewise, when certain circumstances apply and it is technically feasible, data subjects will have the right to have their personal data transmitted directly to another controller or processor, upon request.

To exercise the rights indicated above, you must contact us in writing at: GRUPO ALINVENTOR DESARROLLO ESTRATEGICO, S.L., AV Salamanca, 14, 1, Alicante/Alacant, Alicante, 03005, or by email at info@mindden.com. We recommend that you enclose a copy of your national ID with your request.

Likewise, if you consider that the processing of your personal data does not comply with the applicable legislation, you have the right to lodge a complaint with the supervisory authority, the Spanish Data Protection Agency (www.aepd.es).

Principles applicable to the processing of personal data

The Personal Data Protection Policy is a measure of proactive accountability, intended to ensure compliance with the applicable legislation in this area and, in connection with it, respect for the right to honour and privacy in the processing of the personal data of all persons who deal with GRUPO ALINVENTOR DESARROLLO ESTRATEGICO, S.L. GRUPO ALINVENTOR DESARROLLO ESTRATEGICO, S.L. will ensure compliance with the following principles:

Lawfulness, fairness, transparency and purpose limitation. Data processing must always be notified to the data subject through established clauses and procedures; and it will only be considered legitimate if there is consent for the processing (with special attention to that given by minors), or if it has another valid legal basis, and its purpose is in accordance with the applicable legislation.
Data minimisation. The data processed must be adequate, relevant and limited to what is necessary in relation to the various purposes of the processing.
Accuracy. Data must be accurate and, where necessary, kept up to date. To this end, the necessary measures will be taken to erase or rectify without delay any personal data that is inaccurate with respect to the purposes of the processing.
Storage limitation. Data will be kept in a form that permits the identification of data subjects for no longer than necessary for the purposes of the processing in question.
Integrity and confidentiality. Personal data will be processed in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, through the application of appropriate technical or organisational measures.
Data disclosures. The purchase or obtaining of personal data originating from illegitimate sources is prohibited, as are cases in which such data has been collected or disclosed in breach of the law or its legitimate origin is not sufficiently guaranteed.
Engagement of providers with access to data. Only providers that offer sufficient guarantees to apply appropriate technical and security measures in data processing will be selected. The corresponding contract will be documented with them in this regard.
International data transfers. Any processing of personal data subject to European Union legislation that involves a transfer of data outside the European Economic Area must be carried out in strict compliance with the requirements established in the applicable law.
Rights of data subjects. The organisation will facilitate for data subjects the exercise of the rights of access, rectification, erasure, restriction of processing, objection and portability, establishing for this purpose the internal procedures and, in particular, the forms necessary and appropriate for their exercise.

Personal data of minors

In accordance with Article 8 of the GDPR and Article 7 of Spanish Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights, only persons over 14 years of age may lawfully give their consent to the processing of their personal data by GRUPO ALINVENTOR DESARROLLO ESTRATEGICO, S.L. In the case of a minor under 14 years of age, the consent of parents or guardians will be required for the processing, and it will only be considered lawful to the extent that they have authorised it.

Secrecy and security of personal data

GRUPO ALINVENTOR DESARROLLO ESTRATEGICO, S.L. undertakes to notify the user, without undue delay, when a personal data security breach occurs that is likely to result in a high risk to their rights and freedoms. In accordance with Article 4 of the GDPR, a personal data breach is understood to mean any breach of security leading to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of, or access to, such data.

Personal data will be treated as confidential by the data controller, who undertakes to inform and ensure, by means of a legal or contractual obligation, that such confidentiality is respected by its employees, associates and any person to whom the information is made accessible.

Privacy policy