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PRIVACY & DATA PROTECTION POLICY

DATA CONTROLLER

In accordance with Regulation (EU) 2016/679, the General Data Protection Regulation, and Spanish Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights, we inform you that the controller of your personal data is MARINA PORT VELL S.A.U., with tax identification number A59733584 and registered office at calle Escar, 26, 08039 Barcelona. For any matter relating to the processing of your personal data, you may contact us at [email protected].

 

PURPOSES

We may process your personal data for one or more of the following purposes:

 

1. REQUESTS FOR INFORMATION

Where you request information about the services offered by MARINA PORT VELL S.A.U. or the activities it organises, we will process your personal data in order to provide the information requested and, where applicable, to send you additional information, including periodic communications such as newsletters, by any means, including electronic means (email, SMS, MMS, social media, etc.).

2. CUSTOMERS

Where you wish to contract any of the marina’s services, we will process your personal data in order to manage the commercial relationship, including commercial information, quotations, contracting, service provision, accounting, payment collection, customer service and related matters.

3. SUPPLIERS

Where you are, or intend to become, a supplier of MARINA PORT VELL S.A.U., we will process your personal data in order to manage commercial information, orders, procurement or use of your products and/or services, accounting, payments, after-sales service and related matters.

4. CANDIDATES

Where you apply for a vacant position at MARINA PORT VELL S.A.U. and provide us with your professional background, we will process your personal data in order to manage your participation in recruitment processes, assess your application, verify the suitability of your profile for the position offered and contact you during the recruitment process. In addition, and only where you expressly authorise us to do so, we may retain your curriculum vitae and include your data in our talent pool in order to consider your application for future vacancies that may match your professional profile.

5. NEWSLETTER

Where you subscribe to our newsletter or to other electronic information services, we will process your personal data in order to send you news, updates, information about events and activities, services and commercial communications relating to MARINA PORT VELL S.A.U. by electronic or equivalent means.

6. WEB FORMS

Where you complete any of the forms available on our website, we will process your personal data in order to handle, manage and respond to your request, query, information request, booking or any other matter related to the purpose of the relevant form.

7. PROFESSIONAL CONTACTS

Where you maintain a professional relationship with MARINA PORT VELL S.A.U. or act on behalf of a customer, supplier, collaborating entity or potential business partner, we will process your professional contact details in order to manage the existing commercial or professional relationship, maintain appropriate communications and coordinate the activities arising from that relationship.

8. VIDEO SURVEILLANCE

In order to ensure the security of persons, facilities, vessels and other assets located in the facilities managed by MARINA PORT VELL S.A.U., certain areas may be monitored by video surveillance systems. The images captured will be used exclusively for security, access control, incident prevention and the investigation of possible unlawful acts or acts contrary to applicable regulations.

 

LEGAL BASIS

MARINA PORT VELL S.A.U. will process your personal data where one or more of the following legal bases applies:

 

1. REQUESTS FOR INFORMATION

Where you request information, the legal basis for the processing is your freely given, informed, specific and affirmative consent, provided by submitting the relevant form or contacting us by email.

2. CUSTOMERS AND SUPPLIERS

Where you are a customer or supplier of MARINA PORT VELL S.A.U., the legal basis for the processing is the performance of the contractual relationship to which you are a party.

3. CANDIDATES

Where you apply for a vacancy at MARINA PORT VELL S.A.U. and provide us with your professional background, the legal basis for the processing is the taking of steps at your request prior to entering into an employment or similar contractual relationship, for the purposes of your participation in the recruitment process. Where you authorise us to retain your curriculum vitae for future professional opportunities other than the specific recruitment process for which you have applied, the legal basis for the processing is your consent, which you may withdraw at any time.

4. NEWSLETTER

Where you subscribe to our newsletter or informational communications, the legal basis for the processing is the consent given by the data subject or, where legally applicable, the legitimate interest of MARINA PORT VELL S.A.U., in accordance with the applicable regulations on information society services and electronic commerce.

5. WEB FORMS

In relation to requests submitted through web forms, the legal basis for the processing is the data subject’s consent and/or the taking of steps prior to entering into a contract at the data subject’s request, depending on the nature of the request submitted.

6. PROFESSIONAL CONTACTS

In relation to the contact details of professionals and representatives of legal persons, the legal basis for the processing is the legitimate interest of MARINA PORT VELL S.A.U. in maintaining commercial and professional relationships with the entity for which they provide services, in accordance with Article 19 of Spanish Organic Law 3/2018.

7. VIDEO SURVEILLANCE

In relation to video surveillance systems, the legal basis for the processing is the legitimate interest of MARINA PORT VELL S.A.U. in ensuring the security of persons, facilities, vessels, equipment and other assets located within the port premises.

 

DATA RETENTION PERIOD

 

1. REQUESTS FOR INFORMATION

Where you request information, your personal data will be retained until you request its erasure or withdraw your consent.

2. CUSTOMERS AND SUPPLIERS

Where you are a customer or supplier of MARINA PORT VELL S.A.U., your personal data will be retained for the duration of the contractual relationship and, thereafter, for the periods required to comply with legal obligations and address any liabilities that may arise from the processing.

3. CANDIDATES

Where you participate in a recruitment process, your personal data will be retained for as long as necessary to manage that process. Where you have expressly consented to the retention of your curriculum vitae for future professional opportunities, your data may remain in our talent pool for a maximum period of one (1) year from receipt or until you withdraw your consent, whichever occurs first.

4. NEWSLETTER

Personal data processed in connection with subscription to the newsletter will be retained until the data subject unsubscribes or withdraws consent.

5. WEB FORMS

Personal data provided through web forms will be retained for as long as necessary to handle the request submitted and, thereafter, for the legally applicable retention periods.

6. PROFESSIONAL CONTACTS

Professional contact details will be retained for as long as the professional or commercial relationship remains in force and, thereafter, for the limitation periods applicable to any legal liabilities that may arise.

7. VIDEO SURVEILLANCE

Images captured by video surveillance systems will be retained for a maximum period of one (1) month from capture, unless they must be retained for a longer period in order to evidence the commission of acts affecting the integrity of persons, assets or facilities, or where requested by a competent authority.

 

RECIPIENTS OF PERSONAL DATA

Personal data may be disclosed to third parties where required by law, where necessary for the performance of a contractual relationship, or where the data subject has given consent.

In addition, personal data may be accessed by service providers acting as processors, where their involvement is necessary for the conduct of MARINA PORT VELL S.A.U.’s business activities, including, by way of example and without limitation:

  • providers of IT services, web hosting, maintenance and technological support;

  • providers of email services, electronic communications, cloud storage and collaborative tools;

  • providers of web form management platforms, newsletters and commercial communications;

  • providers of video surveillance and security services;

  • legal, tax, employment and other external professional advisers;

  • banks and payment service providers;

  • auditors, insurers and other providers whose involvement is necessary for the provision of services or for compliance with legal obligations.

For the purpose of managing professional and commercial relationships, certain professional contact details may be disclosed to customers, suppliers, collaborators, port authorities, public administrations or other entities related to the activities of MARINA PORT VELL S.A.U., where such disclosure is necessary for the development of the professional or commercial relationship, the management of the services provided or compliance with legal obligations.

Images obtained through video surveillance systems will only be disclosed to law enforcement authorities, courts and tribunals, port authorities or competent public administrations where there is a legal obligation, a request from a competent authority, or where necessary for the investigation of incidents affecting the security of persons, vessels, facilities or assets of MARINA PORT VELL S.A.U.

 

INTERNATIONAL DATA TRANSFERS

As a general rule, personal data will be processed within the European Economic Area.

However, certain service providers engaged by MARINA PORT VELL S.A.U. for the provision of technological services, information hosting, email, electronic communications, web form management, newsletter delivery, cloud storage, IT support or other business management tools may be located outside the European Economic Area or may access personal data from third countries.

In such cases, MARINA PORT VELL S.A.U. will implement the appropriate safeguards required under data protection legislation to ensure a level of protection essentially equivalent to that guaranteed in the European Union. Such safeguards may include, among others, an adequacy decision adopted by the European Commission for the destination country or the execution of the Standard Contractual Clauses approved by the European Commission, together with any supplementary measures that may be necessary.

Data subjects may request further information about international data transfers and the safeguards applied by contacting MARINA PORT VELL S.A.U. through the contact channels indicated in this Privacy Policy.

 

SECURITY MEASURES

MARINA PORT VELL S.A.U. implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of personal data, in accordance with Regulation (EU) 2016/679 and other applicable data protection legislation.

These measures are designed to protect personal data against destruction, loss, alteration, unauthorised disclosure, unauthorised access or any other form of unlawful processing, taking into account the state of the art, the nature of the data processed, the context and purposes of the processing, as well as the risks to the rights and freedoms of natural persons.

MARINA PORT VELL S.A.U. also requires its suppliers and collaborators with access to personal data to implement appropriate security measures equivalent to those required by applicable legislation, and to enter into the relevant data processing agreements where required.

Nevertheless, data subjects should be aware that security measures on the Internet are not absolute and that, despite the adoption of reasonable and appropriate measures, the absolute security of information cannot be guaranteed.

 

RIGHTS OF DATA SUBJECTS

Data subjects may exercise, at any time, the rights recognised under data protection legislation and, in particular, the rights of access, rectification, erasure, objection, restriction of processing and data portability, as well as the right not to be subject to a decision based solely on automated processing of their data, including profiling, where applicable.

In addition, where processing is based on the data subject’s consent, the data subject may withdraw such consent at any time, without affecting the lawfulness of processing carried out prior to such withdrawal.

To exercise their rights, data subjects may send a written communication to MARINA PORT VELL S.A.U., c/ Escar, 26, 08039 Barcelona, or submit a request to the email address provided for this purpose [email protected].

The request must allow the data subject to be sufficiently identified and must specify the right to be exercised. Where there are reasonable doubts as to the identity of the requester, MARINA PORT VELL S.A.U. may request the additional information strictly necessary to verify their identity.

Where a request is submitted through a representative, the representation granted must be duly evidenced.

Data subjects also have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD) if they consider that the processing of their personal data infringes applicable data protection legislation. Further information is available on the website of the Spanish Data Protection Agency: https://www.aepd.es.

In the event of any discrepancy between the Spanish version and any translated version of this document, the Spanish version shall prevail.