PRIVACY POLICY OF THE CORPORATE WEBSITE

ELIX POLYMERS declares that it is fully compliant with the prevailing Spanish and European law regarding the Protection of Personal Data, in particular with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, and with the Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights.

Your privacy and trust are important to us, which is why in this Privacy Policy we provide you with important information on how we process your personal data. We invite you to carefully read what is hereafter stated, and if any question should arise, please contact us through the means that we place at your disposal.

Data controller.

The Controller of your personal data and owner of this website is ELIX POLYMERS, S.L.U. (“ELIX POLYMERS”), a mercantile company registered at the Tarragona Mercantile Registry in Volume 2379, Folio 225, Section 8, Page T-35381, 24th Inscription, holder of tax identification code Nº B-63508352 and domiciled at Carretera de Vilaseca – La Canonja S/N 43110 La Canonja - Tarragona (Spain).

In addition to the address mentioned above, if you would like to contact us please use any of the following means:

Typology, purpose and legitimate aim of the processing of personal data

We collect personal data from:

Employees. These data are used to manage the labor relationship, for payroll management, workday control and all other obligations that the work relationship entails. The data collected comprise identifying information, data of special categories (health/disability), personal characteristics information, academic and professional background, employment details and financial details. The legitimate bases for the processing of these data are the relationship between the parties, the legal obligation to gather these types of data and the consent of those concerned. The conservation period of these data shall be of 5 years from the date of termination of the work relationship, except for payroll information and the Spanish Social Security forms TC1 and TC2, which must be retained for 10 years.

Job applicants. These data are gathered with the aim of conducting selection processes, and affect such categories as identification details, personal characteristics information, academic and professional background and employment details. The lawful bases for processing these data are the pre-contractual relationship between the parties involved and the consent expressed by the affected individuals. All data shall be destroyed within 6 months of the date of termination of the selection process.

Potential clients. The purpose for which these data are processed is the business management of potential clients. The data gathered comprise identifying data and commercial information. The performance of a pre-contract and the legitimate interest of the Data Controller constitute the legitimate bases for the processing. The conservation period of the data is 5 years from the date of termination of the contract with the potential client.

Customers. These data are processed for the performance of a commercial contract or pre-contract and for the provision of the ordered goods. To those ends identifying information and financial details are requested. The lawful bases for processing are the legitimate interest of the Data Controller and the performance of a contract. The data shall be deleted within 5 years of the termination of the business relationship.

Suppliers. These data are used to manage the commercial contracts, and for this purpose are collected identifying data, financial or fiscal information and other data from sources such as the Spanish Social Security form TC2 or civil liability insurance policies. It is the contract or pre-contract itself that gives us the legitimacy to processes your data, which shall be deleted within 5 years of the termination of the business relationship.

Management Board members. The processing of data in this instance is aimed at managing the company at an internal level. The legitimate basis for the processing is the business relationship between the parties.

Video surveillance. These data are used to ensure safety at our facilities. The legitimate basis for processing is the performance of a mission undertaken in the public interest. These data (the images) shall be deleted within a period of not more than 30 days.

Sending of commercial communications. The data are processed in order to send commercial communications or newsletters, for which end identification details are requested. The consent of the interested party is the basis of legitimacy for the processing. Data shall be deleted once the processing is finalized, namely when the interested party has opted out of these communications.

Replies to queries. We collect the contact details with which you identify yourself to communicate with us, namely your e-mail, phone number or postal address, as well as any other data that you may freely submit to us, a content which at present cannot be defined as it depends on what you eventually wish to provide. We process these personal data with the purpose of answering your queries, as well as to address your rights regarding personal data protection. The legitimate bases for responding to your communications are your consent and the legitimate interest of ELIX POLYMERS in responding to your queries. These data shall be deleted within 2 years.

Exercise of rights. These data are used to satisfy the exercise of data protection rights. Compliance with the rules in force regarding data protection constitutes the legitimate grounds for the processing. These data shall at all times be minimized and stored in conformity with data protection regulations.

Whistleblower channel. These data are processed to handle complaints received as a result of a lack of compliance with the document of Duties and Obligations of the staff, the Code of Conduct and other internal standards. The lawful basis for processing is the legitimate interest of the Data Controller. These data shall be minimized and retained for 7 days unless they are subject to investigation, in which case they shall be kept for the duration of said investigation, the corresponding judicial proceeding or the limitation period of such actions as may be exercised.

Use of Cookies. ELIX POLYMERS may process personal data collected by the cookies indicated in its Cookies Policy. In this case your personal data shall be processed with technical, statistic and analytic purposes with which certain functions that are considered essential are carried out. Your consent constitutes the legitimate basis for the processing of these data.

Conservation period

The personal data provided will be kept for as long as a contractual relationship between us exists, for the lawful period of data storage, or until the User requests to exercise his or her rights of deletion or objection. On a general basis, there shall be a conservation period of 5 years from the date of termination of the relationship between the parties. Once finalized, the data shall be confidentially canceled or destroyed.

How do we share user information?

We share personal data with third parties with the aim of providing services under the terms of this Privacy Policy, or when we consider it permitted or required by law. When we share personal information we do it in accordance with all data privacy and security requirements.

ELIX POLYMERS informs the stakeholder that some of our providers may process his or her personal data in their capacity as Data Processors, for example in the case of:

  • hird party service providers, when necessary for the provision of services, activity coordination, internal management, supplier certification, software, systems and platforms support, cloud hosting services and electronic communications. In such cases, the data transfer to a third party will only be carried out when ELIX POLYMERS is in a contractual relationship with the Data Processor that ensures its confidentiality, the non-use of the personal information that we make available to the Processor for any purposes other than the stated above, and the fulfillment of our internal rules on the privacy and security of the information.
  • When the data transfer is covered by a legal obligation, or it is requested by the competent authorities in order to respond to legal demands, to a criminal investigation of a possible illegal activity, or to any claims stating that certain content violates the rights of third parties; or when necessary to protect the rights, property or security of third parties, or in the case of merger, purchase or sale, restructuring, joint venture, assignment, transfer or any other disposal, either partial or total, of our business, assets or stocks. (For example, transfers to the Spanish Tax Agency, to the Spanish Social Security Treasury, etc.).

International data transfers

When pertinent, ELIX POLYMERS uses third party tools and services to manage some services. Certain such services may be owned by third parties outside of the European Economic Area.

ELIX POLYMERS seeks to use secure tools whose servers are preferably located in Spain, or in their absence in a member state of the European Union, or outside of the European Union provided that the European regulations are met, in accordance with the guidelines and recommendations of the Spanish Data Protection Agency, the European Commission and the relevant Community agreements in matters of international data transfer.

In case that an international data transfer is needed, acceptance of this Privacy Policy implies that, as User, you explicitly consent to the aforementioned transfer.

Exercise of rights and appeal to the Spanish Data Protection Agency

The personal data provided will be kept for as long as a contractual relationship between us exists, for the lawful period of data storage, or until the User requests to exercise his or her rights of deletion or objection. On a general basis, there shall be a conservation period of 5 years from the date of termination of the relationship between the parties. Once finalized, the data shall be confidentially canceled or destroyed.

Users may at any time withdraw their consent and/or exercise their rights of access, rectification, erasure, restriction, objection and portability provided for in the European personal data protection law, by sending an e-mail to privacy@elix-polymers.com or by post to ELIX POLYMERS SLU, at Carretera de Vilaseca – La Canonja S/N 43110 La Canonja - Tarragona (Spain).

The User must clearly indicate the right that he or she wishes to exercise and send a copy of his or her National ID Card or any other valid identity document which legitimizes him or her, including that which enables electronic identification.

If you have not been duly attended to in the exercise of your rights, you may lodge a complaint with the Spanish Data Protection Agency.

Your commitment: the veracity of the transmitted data

The personal data provided will be kept for as long as a contractual relationship between us exists, for the lawful period of data storage, or until the User requests to exercise his or her rights of deletion or objection. On a general basis, there shall be a conservation period of 5 years from the date of termination of the relationship between the parties. Once finalized, the data shall be confidentially canceled or destroyed. 

The User declares that the personal data that he or she provides to ELIX POLYMERS are true.

As User, you should be aware that you are solely responsible for any direct or indirect damages or losses caused to ELIX POLYMERS as the entity responsible for this website or to any third party, if you send us false data or third-party data without the previous consent of said parties, causing as a result deception, loss or damage.

In order to keep the personal data that we possess accurate and updated, we ask the User to please inform us of any variations that might take place within the provided personal data.

Consent of minors

ELIX POLYMERS prohibits users under 14 the transfer of personal data through this website or by any means provided therein. In case ELIX POLYMERS identifies users that could be under the required age, it will not process their data nor will it answer their requests.

In case ELIX POLYMERS has a reasonable suspicion that the User might be a minor, it reserves the right to request a copy of the User's National ID Card or equivalent document that demonstrates the User's legal capacity.

Applicable security measures

In order to protect the personal data of the Users, ELIX POLYMERS verifies its own compliance and monitors its Data Processors on the implementation of appropriate technical and organizational measures that are consistent with the level of technology available, taking into account the extent, content and purpose of the processing as well as the probability and possible seriousness of the risks that the rights and freedoms of the stakeholders may confront, seeking to ensure the confidentiality, availability and resilience of the processing systems and services.

Our information security policies and procedures are regularly reviewed and updated, to meet our business needs, the technological changes and the policy requirements.

Applicable law and jurisdiction

ELIX POLYMERS is based in Spain. Therefore, the content of this Privacy Policy has been drafted to be consistent with the Spanish legislation and the applicable law of the European Union.

By agreeing to this Policy, the User accepts that any and all claims or complaints against ELIX POLYMERS derived from or related to the use of this website, and more specifically to the processing of the User’s personal data, will be addressed by the competent courts of Tarragona. Should ELIX POLYMERS wish to file a claim, it will do so before the competent court of the User's domicile, or of the domicile of ELIX POLYMERS (Carretera de Vilaseca S/N La Canonja, 43110 La Canonja (Tarragona – Spain)) in the case of taking action against legal persons or professionals that are non-consumers.

If the User accesses this Site from a location outside Spain, he or she is responsible for compliance with all applicable laws, local and international, that may apply.

Last update

Privacy Policy last updated: December 12th, 2020.

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