| CONTROLLER | BENOW PARTNERS, S.L.P. (“BENOW” or the “Firm”).
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| PURPOSES |
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| LAWFUL BASIS |
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| DISCLOSURES | The personal data provided will be disclosed only if necessary for the execution of the purposes described to our service providers and partners when required for the contracted service (including, among others, notaries, court agents, internal management tools, hosting providers or commercial communication services).
Data may also be disclosed to Public Authorities in compliance with the legal obligations applicable to BENOW. |
| RETENTION | Data will be retained for the time necessary to fulfil the purposes for which they were collected, unless consent is withdrawn. Thereafter, where necessary, the information will be blocked for the legally established periods. |
| EXERCISE OF RIGHTS | By writing to: calle Alfonso XII 32, 4º Dcha., Madrid (28014); or by email to lopd@benow.es. |
Pursuant to 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 (the “GDPR”), as well as the applicable national implementing legislation, we hereby inform you of our Privacy Policy governing the processing of personal data you provide to us:
1. DATA CONTROLLER
The company responsible for the processing of your personal data (“Personal Data”) is BENOW PARTNERS, S.L.P., with Tax ID No. B – 86.759.693 and registered address at Calle Alfonso XII 32, 4º Dcha., Madrid (28014), Spain (“BENOW” or the “Firm”), email: info@benow.es
You may contact the Firm at info@benow.es for any queries relating to the processing of your Personal Data by BENOW.
This Privacy Policy defines the processing that the Firm will carry out on the Personal Data that you, as a user (the “User” or “You”) of the website www.benow.es (the “Website”), freely and knowingly provide through the forms (“Forms”) made available by BENOW, and/or as a client following the execution of our services proposal, for the purposes set out in the following section.
2. PURPOSES OS PROCESSING
The User’s Personal Data collected through the Forms available on the Website are processed by BENOW for the following purposes:
- Provision of legal services contracted by the client with BENOW.
- Management of enquiries submitted through our contact form on the Website.
- Evaluation of resumes received in recruitment processes to work with us.
- Sending commercial communications of interest to our clients based on services previously rendered.
BENOW will only collect the Personal Data necessary for the correct fulfilment of the requested purposes, based on the freely, informed and unequivocally given consent expressed through acceptance of this Privacy Policy.
3. LAWFUL BASIS FOR PROCESSING PERSONAL DATA
The purposes of the processing described in the previous section correspond to the following lawful basis:
| PURPOSES | LAWFUL BASIS |
| Provision of legal services. | Processing is necessary for the contractual or pre-contractual relationship in which the data subject is a party. |
| Enquiries made through our contact Form. | Consent provided by the data subject. |
| Evaluation of resumes received in recruitment processes. | Consent provided by the data subject, as well as necessity arising from the pre-contractual relationship in which the data subject is a party. |
| Sending of commercial communications. | Satisfaction of the legitimate interests pursued by BENOW in informing clients of new services or sending updates of interest. |
4. THIRD-PARTY DATA
In principle, we process data provided by the User and/or client. However, where personal data belonging to third parties are provided to us, the User warrants that such third parties have been informed of this Privacy Policy and assume responsibility for any damage, whether direct or indirect, that may arise as a consequence of providing such personal data.
Additionally, some resumes may be provided by partner entities such as business schools, universities or recruitment companies with whom we have executed the relevant cooperation agreements.
5. ACCURACY OF DATA
The User guarantees that the Personal Data provided are accurate and undertakes to inform BENOW of any modification thereto. The User shall be liable for the accuracy of the Personal Data provided, and the Firm shall be held harmless from all liability arising from failure to achieve the intended purpose due to inaccurate or outdated data.
6. DATA RETENTION
Personal Data will be retained for the time necessary to fulfil the purposes for which they were collected, unless consent is withdrawn. Thereafter, where necessary, the information will be blocked for the legally established periods.
With respect to Personal Data included in resumes, we will retain them for a period of two years, after which they will be deleted from our files.
7. DISCLOSURE OF PERSONAL DATA
Personal Data provided by Users or clients will be disclosed, whenever necessary for the execution of the purposes described, to our service providers and partners when required for the contracted service (including, among others, notaries, court agents, internal management tools, hosting providers or commercial communication services).
Data may also be disclosed to Public Authorities when such disclosure is required by law or by judicial request.
Where the Firm engages in services that require international data transfers, it will adopt all measures within its reach to ensure that the Personal Data are processed in accordance with the security levels required under applicable law and in compliance with the GDPR, as well as with the instructions and decisions issued by the relevant data protection authorities.
8. USER RIGHTS IN RELATION TO THEIR DATA
As BENOW processes Personal Data, it acts as the data controller. Accordingly, the User, as the data subject, is entitled to exercise the following rights:
Right of access: Data subjects shall be provided with a copy of their personal data held by us, together with the purpose for which they were collected, the identity of the recipients, the envisaged retention periods or the criteria used to determine them.
Right to rectification: Data shall be amended when they are inaccurate or incomplete, having regard to the purposes of the processing. The data subject must specify which data are to be rectified and provide supporting documentation where necessary.
Right to erasure: Data shall be erased when the data subject objects to the processing and there is no legal basis preventing erasure, when the data are no longer necessary for the purposes for which they were collected, when consent is withdrawn and no other lawful basis exists, or where the processing is unlawful.
Right to object: Upon objection by the data subject, the controller shall cease processing provided there is no legal obligation preventing it.
Right to restriction of processing: Data subjects may request the suspension of processing while accuracy is being verified; when processing is based on the controller’s legitimate interest or the performance of a task in the public interest, pending verification of whether such grounds override the interests, rights and freedoms of the data subject; when processing is unlawful and the data subject requests restriction instead of erasure; or when data are no longer needed by the controller but are required by the data subject for the establishment, exercise or defense of legal claims.
Right to data portability: Where processing is carried out by automated means and is based on consent or is necessary for the performance of a contract, data subjects may request to receive their personal data in a structured, commonly used and machine-readable format, or to have them transmitted directly to a new controller where technically feasible.
The User or client may exercise these rights by emailing lopd@benow.es or by ordinary postal mail at the following address:
BENOW PARTNERS
Calle Alfonso XII 32, 4ºDcha.
Madrid (28014)
Where there are reasonable doubts about the identity of the individual exercising their rights, we may request a copy of an official identity document (ID card, driving licence or passport) to verify the requestor’s identity.
Finally, in accordance with the GDPR, the User is informed that, should they believe that the exercise of their rights has not been properly addressed, they may lodge a complaint with the Spanish Data Protection Agency.
9. DATA SECURITY
Protecting privacy and Personal Data is a core value for BENOW. Accordingly, the Firm maintains the appropriate levels of security in accordance with applicable law and has implemented all technical measures within its reach to prevent loss, misuse, alteration, unauthorized access or theft of Personal Data provided through the Website.
BENOW and its professionals also undertake to comply with the duty of secrecy and confidentiality regarding Personal Data as required under the GDPR.
10. ACCEPTANCE AND CONSENT
The User declares that they have been informed of the conditions relating to the protection of Personal Data and accepts and consents to the processing of such data by BENOW in accordance with this Privacy Policy.
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