1. IDENTIFICATION

• Entity: ECOEMBES ENTIDAD ADMINISTRADORA, S.L.U. (hereinafter, "ECOEMBES").
• Tax Identification Number: B56540040.
• Registered office: Cardenal Marcelo Spínola 14 / 2ª Planta. 28016 Madrid.
• Contact information for the Data Protection Delegate: oficinadeprivacidad@ecoembes.com.

2. GENERAL INFORMATION

Through acceptance of this Privacy Policy, the user is informed that the personal data provided through the web pages owned by ECOEMBES (hereinafter, the "Website") will be processed by ECOEMBES, as well as the data derived from browsing and any other data that may be provided to ECOEMBES in the future.

The user must carefully read this Privacy Policy, which has been drafted in a clear and simple manner, to facilitate its understanding, freely and voluntarily determining whether he/she wishes to provide his/her personal data to ECOEMBES.

The requested data requested in the forms on the Website are, on a general basis, necessary (unless otherwise specified in the required field) to fulfill the established purposes.

Therefore, if the personal data are not provided or are not provided correctly, the purposes cannot be fulfilled.

Notwithstanding the above, you may freely view the content of the Website.

3. FOR WHAT PURPOSE WILL THE USER'S PERSONAL DATA PROCESSED?

The personal data provided through the website or other means made available to users will be processed by ECOEMBES for the following purposes:

1. Attention and management of the requests made through the provided forms: the personal data collected by ECOEMBES will be processed, both automatically and, where appropriate, conventionally in order to contact the user in order to attend to and properly manage the requests made through the forms provided for this purpose. Customer service through the chat on the Website may be provided by the AIRE assistant, which is an automatic software chatbot, which will categorise the query and may direct it to the appropriate person for proper attention.
2. Creation of an account and access to the private area: the provided data for this purpose will be processed to allow the user to create an account and access the private area from which he/she can manage his/her relationship with ECOEMBES.
3. Sending, by electronic means, information related to the recycling activities of ECOEMBES: the provided data will be processed for the purpose of sending the user commercial communications with information that may be of interest to him/her about ECOEMBES products and services, as well as any recycling activity or initiative and other relevant information.

Please bear in mind that you may object to the processing of your data for this purpose at any time by contacting the Privacy Office or via the link included in any commercial communication sent to you. 

4. Profiling with own sources: ECOEMBES will process the data to create a profile with the user's preferences in order to be able to impact them with personalised communications that may be of its interest. ECOEMBES uses its own information.
5. To manage participation in the different projects and initiatives of ECOEMBES: The personal data collected by ECOEMBES will be processed for the purpose of managing participation in the projects and initiatives organised by ECOEMBES. ECOEMBES may contact the user to inform him/her of the status of the project or initiatives in which he/she is interested or other with similar information.
6. Organisation of contest and sweepstakes / giveaways: the provided data will be processed to allow the user to participate in the contest, sweepstakes and giveaways organised by ECOEMBES. Also, in the event of being a winner, to award the corresponding prize.
7. Sending satisfaction surveys: the provided data be processed by ECOEMBES to ascertain the degree of satisfaction of users in relation to the provision of its services, projects, and initiatives.
8. Data provided in the "Work with us" section: the provided data through the sending of CVs in the "Work with us" section of the Website will be processed for the purpose of evaluating the user's candidacy for possible selection processes and/or vacancies in ECOEMBES.
9. Data provided for the exercise of rights: the provided data for the exercise of rights will be processed for the purpose of fulfilling it.
10. Data obtained from the use of the Website: the provided data through the use of the Website will be processed for the purpose of carrying out the maintenance, support and updating of the Website, as well as for the resolution of possible technical or any other incidents that may arise in relation to the same. Likewise, it may be used to measure performance and carry out analyses on access habits and the activity carried out by users on the Website.

Moreover, browsing of the Website by the user may be managed and analysed by means of cookies. The user can obtain more information in this regard in our Cookies Policy. 

4. WHAT CATEGORIES OF USER`S DATA DOES ECOEMBES PROCESS?

ECOEMBES will process the following categories of user data:

1. Attention and management of the requests made through the provided forms: identification data (name and surname); contact data (e-mail, telephone, postcode); any other data provided by the user in his/her query or request.
2. Creation of an account and access to the private area: identification data (name and surname); contact details (e-mail, telephone); employment details (company, position held).
3. Sending, by electronic means, information related to the recycling activities of ECOEMBES: identification data (name and surname); contact data (e-mail, telephone).
4. Profiling with own sources: identification data (name and surname); contact data (e-mail, telephone); data on transactions and services (campaigns in which you have participated, activity with ECOEMBES); data on browsing and use of the Website.
5. To manage participation in the different projects and initiatives of ECOEMBES: identification data (name and surname, ID number); contact data (e-mail, telephone, address); employment details (company, position held); transaction and service data (campaigns or any interaction carried out with ECOEMBES).
6. Organisation of contest and sweepstakes / giveaways: identification data (name and surname, ID card number); contact data (e-mail, telephone, address).
7. Sending satisfaction surveys: identification data (name and surname,); contact data (e-mail, telephone, address); data on transactions and services (campaigns or any interaction carried out with ECOEMBES).
8. Data provided in the "Work with us" section: identification data (name and surname, ID); contact data (e-mail, telephone, address); employment details (company, position held); academic and professional data (academic history, evaluations, studies); personal circumstances data (sex, age, gender); any other data provided in the CV.
9. Data provided for the exercise of rights: identification data (name and surname, ID card number); contact data (address, telephone number, e-mail address); as well as any other data included by the user in the request.
10. Data obtained from the use of the Website: location data through IP's, such as browser or device, data derived from cookies, clicks, interactions, etc.

If the user provides data of third parties, he/she declares that he/she has their consent and undertakes to provide them with the information contained in the Privacy Policy, exempting ECOEMBES from any liability in this regard. However, ECOEMBES may carry out periodic checks to verify this fact, adopting the corresponding due diligence measures, in accordance with data protection regulations.

5. WHAT IS THE LAWFULL BASIS FOR THE PROCESSING OF USER DATA?

The personal data provided through the website or other means made available to users will be processed by ECOEMBES for the following purposes:

1. Attention and management of the requests made through the provided forms: the lawful basis for this processing is the legitimate interest of ECOEMBES, which consists in correctly dealing with the requests made by users and providing a satisfactory customer service experience. Please bear in mind that you may object to the processing of your data for this purpose at any time by contacting the Privacy Office.
2. Creation of an account and access to the private area: the lawful basis for the processing of data for this purpose will be the execution of the contractual relationship between the user and ECOEMBES.
3. Sending, by electronic means, information related to the recycling activities of ECOEMBES: the lawful basis for this processing will be, on the one hand, the legitimate interest of ECOEMBES by virtue of article 21.2 of  Ley 34/2002, de 11 de julio, de servicios de la sociedad de la información y de comercio electrónico, in the event that the user is a customer or associate of ECOEMBES, in order to  send information related or similar to the product or service originally contracted.  On the other hand the lawful basis could be consent, in the event that the user is not a client or associate of ECOEMBES or the commercial information sent is of a generic nature.

Please bear in mind that you may object to the processing of your data for this purpose at any time by contacting the Privacy Office or via the link included in any commercial communication sent to you. 

4. Profiling with own sources: the lawful basis for this processing is the legitimate interest of ECOEMBES, which consists in being able to send the user information that may be of his or her interest. Please bear in mind that you may object to the processing of your data for this purpose at any time by contacting the Privacy Office.
5. To manage participation in the different projects and initiatives of ECOEMBES: the lawful basis for this processing is the execution of the contractual relationship between the user and ECOEMBES.
6. Organisation of contest and sweepstakes / giveaways: the lawful basis for this processing is the execution of the contractual relationship between the user and ECOEMBES.
7. Sending satisfaction surveys: the lawful basis for this processing is the legitimate interest of ECOEMBES, consisting of knowing the degree of satisfaction of its users with its services and being able to constantly improve their experience based on the responses. Please bear in mind that you may object to the processing of your data for this purpose at any time by contacting the Privacy Office.
8. Data provided in the "Work with us" section: If the user chooses to submit a spontaneous application, the lawful basis for this processing is the consent of the user, while, in cases where the user applies for an open and specific position, the lawful basis will be the pre-contractual relationship established between the user and ECOEMBES. Please bear in mind that you may object to the processing of your data for this purpose at any time by contacting the Privacy Office.
9. Data provided for the exercise of rights: the lawful basis for this processing is the legal obligation of ECOEMBES to manage such rights in accordance with the applicable regulations.
10. Data obtained from the use of the Website: the legitimate interest of ECOEMBES in the correct functioning of the Website is the lawful basis for the processing of such data for the purpose of maintaining the security of the Website and carrying out its maintenance. In this regard, to avoid interfering with the rights and freedoms of users, no specific data will be processed, as the information is used in aggregate form. Likewise, ECOEMBES has implemented technical security measures to guarantee the privacy and confidentiality of the information processed. If you wish to obtain more information about this processing, you can request it by sending an e-mail to oficinadeprivacidad@ecoembes.com.

Moreover, the lawful basis of the processing of such data for the purpose of measuring performance and analytics will be the consent of the user, which may be revoked at any time and free of charge, without affecting the lawfulness of the processing previously carried out.

The consents granted for the aforementioned purposes are individual and independent, and therefore the user may revoke only one of them without affecting the others or the lawfulness of the processing previously carried out.

To revoke these consents, the user may contact ECOEMBES through the following channels:

• E-mail: oficinadeprivacidad@ecoembes.com.

If the data subject does not provide the aforementioned data or if its incorrect or inaccurate, we will not be able to attend to your request, making it impossible to provide you with the information requested or to carry out the contracting of the services. Therefore, the data controller, ECOEMBES, will be exonerated from any liability that may arise from the non-execution of the professional assignment or from the consequences that may arise from this inaccurate or erroneous information.

6.  TO WHICH RECIPIENTS WILL YOUR DATA BE COMMUNICATED?

• Public Administrations with competence in the matter.
• Courts and Tribunals, in the event of specific requirements made in accordance with the applicable regulations.
• State Security Authorities and Forces, in the event of specific requirements made in accordance with the applicable regulations.
• ECOEMBALAJES ESPAÑA, S.A., for the purpose of centralising the administrative management, by virtue of ECOEMBES` legitimate interest as set in Recital 48 of the RGPD.

Additionally, ECOEMBES will contract the provision of services by third-party suppliers that might have access to the user´s personal data to carry out their activities, or for the fulfilment of the legal obligations and/or the aforementioned purposes. These suppliers will not process your data for their own purposes.

ECOEMBES will contract the provision of services by third parties who carry out their activity, by way of example but not limited to, in the following areas: cloud or computer hosting, sending commercial communications, legal advice.

In this regard, ECOEMBES follows strict criteria for the selection of service providers in order to comply with its data protection obligations and undertakes to enter into a data processing agreement, as required by law, imposing on them, among others, the following obligations: to implement appropriate technical and organisational measures to ensure the security of personal data; to process personal data for the agreed purposes and only in accordance with the documented instructions of the data controller; and to delete and return the data to the data controller once the services have been completed.

Some of the service providers are in countries outside the European Economic Area ("EEA").

The location of these entities outside the EEA implies the existence of an international transfer of personal data. However, ECOEMBES has implemented measures to ensure that such transfers do diminishes the protection of user´s personal data.

In this regard, service providers outside the EEA have signed the corresponding standard contractual clauses approved by the European Commission ("SCC"), an agreement signed between both entities whereby the non-EU company guarantees that it applies European data protection standards. Likewise, many of these providers are certified and adhere to the Data Privacy Framework endorsed by the European Commission.

As a result, the use of these providers does not result in a poorer protection of your personal data.

You can request a copy of these SCC by sending a request to oficinadeprivacidad@ecoembes.com.

7. COMMUNICATIONS

Law  34/2002, de 11 de julio, de servicios de la sociedad de la información y de comercio electrónico, allows commercial communications to be sent through Internet and other electronic means, provided that they can be identified as such, as well as the entity from which they are sent.

ECOEMBES will send commercial communications by email about similar services that may be of interest to the user.

However, ECOEMBES will offer the recipient the possibility of objecting the processing of their data for promotional purposes, both at the time of data collection and in each of the commercial communications sent to them.

Users may unsubscribe from these communications by sending an email to the registered office of ECOEMBES indicated above or to the following e-mail address oficinadeprivacidad@ecoembes.com, indicating "unsubscribe from commercial communications".

8. ECOEMBES PROFILE ON SOCIAL NETWORKS

ECOEMBES has several social networks. When you interact with any of our pages on social networks, the processing of data will be governed by the terms of use, privacy policies and access regulations belonging to the corresponding social network that have been previously accepted by the user.

ECOEMBES will process your data in order to correctly manage its presence on the social network, informing you of activities, products or services, as well as for any other purpose that the regulations of the social networks allow.

Please note that we have no control over the information that the social network collects or how it processes it.

9. STORAGE OF DATA

ECOEMBES will only store users' personal data for the time necessary to carry out the purposes for which they were collected. Subsequently, if necessary, ECOEMBES will keep the information blocked until the prescription of any legal liabilities that may have arisen because of the processing of the users' personal data, at which time the data will be irreversibly erase.

1. Attention and management of the requests made through the provided forms: the data will be stored for the period necessary to process and reply to your request and, once this period has expired, will be blocked for the period of limitation of the legal actions derived from the aforementioned request.
2. Creation of an account and access to the private area: the data will be stored for as long as the user account is active on the Website and, once the account is closed, will be blocked for the period of limitation of any legal action that may arise from its use.
3. Sending, by electronic means, information related to the recycling activities of ECOEMBES: the data will be stored as long as the user does not revoke the consent given for this purpose or objects the processing and, once revoked or objected, the data will be blocked during the period of limitation of the legal actions that may arise.
4. Profiling with own sources: the data will be stored as long as the user does not object to the processing and, once the user has objected, blocked during the period of limitation of the legal actions that may derive.
5. To manage participation in the different projects and initiatives of ECOEMBES: the data will be stored for as long as the relationship with ECOEMBES is maintained and, once it has ended, the data will be blocked during the period of limitation of the legal actions that may arise from its use.
6. Organisation of contest and sweepstakes / giveaways: the data will be stored for as long as the contest or sweepstake / giveaway is held and the prize is awarded and, once it has ended, the data will be blocked for the period of limitation of any legal actions that may arise from its use.
7. Sending satisfaction surveys: the data will be stored for as long as the user does not object to the processing and, once the user has objected, the data will be blocked for the period of limitation of the legal actions that may arise from this.
8. Data provided in the "Work with us" section: the data will be stored until the corresponding recruitment process is held and finalised. Once completed, the data will be erased and blocked during the period of limitation of the legal actions that may arise from the application, unless the user gives his/her consent again for ECOEMBES to keep the data for an additional period of two years and thus keep him/her informed of new vacancies that may fit his/her professional profile.
9. Data provided for the exercise of rights: the data will be stored for the period necessary to manage and process the rights exercised and, once this period has expired, for the period of limitation of the legal actions that may arise from the contractual relationship.
10. Data obtained from the use of the Website: the data will be stored for a period of two years or until the user objects. ECOEMBES may keep the information in aggregate form, without identifying users, for a longer period.
11. USER'S RESPONSIBILITY

The user:

• Guarantees that he/she is over fourteen (14) years old and that the data he/she provides to ECOEMBES is true, accurate, complete, and up to date. The user is responsible for the veracity of all the data he/she communicates and will keep the information provided suitably updated, so that it corresponds to his/her real situation.
• He/she guarantees that he/she has informed the third parties from whom he/she provides his/her data, if he/she does so, of the aspects contained in this document. Likewise, you guarantee that you have obtained their authorisation to provide their data to ECOEMBES for the aforementioned purposes.
• You shall be liable for any false or inaccurate information that you provide through the Website and for any direct or indirect damages that this may cause to ECOEMBES or third parties.

11. EXERCISE OF RIGHTS

As data subject, the user may send an email to ECOEMBES at any time and free of charge, to the address established in the heading of this Privacy Policy, or by e-mail to the address: oficinadeprivacidad@ecoembes.com, providing any proof of its identity, in order to exercise the following rights:

1. Right of access: You will have the right to be informed by ECOEMBES as to whether or not it is processing your personal data and, if so, to have access to such data and to receive information on the purposes for which they are processed, the categories of data affected by the processing, the recipients to whom your personal data were communicated and the expected period for which the data will be kept, among other information.
2. Right to rectification and to erasure: You have the right to request the erasure of personal data provided that the legal requirements are met and also the right to the rectification of inaccurate data concerning you when, among other reasons, such data are no longer necessary for the purposes for which they were collected.
3. Restriction of the processing, revocation of consent and total or partial objection to the processing: In some circumstances (e.g. in case the applicant disputes the accuracy of his or her data, while the accuracy of the data is being verified), you may request that we restrict the processing of your personal data, which will only be processed for the exercise or defence of claims. You also have the right to revoke the consent given and to object to the processing at any time, on grounds relating to your situation, if the processing is based on our legitimate interest. In this case, ECOEMBES will cease processing, unless legitimate reasons can be demonstrated.
4. Right to data portability: You will have the right to receive the personal data you have provided to ECOEMBES in a structured, common, and machine-readable format, and to be able to transmit them to another data controller without being prevented from doing so by the data controller to whom you have provided them, in the cases legally provided for this purpose.
5. Automated individual decision-making: Likewise, in addition to the aforementioned rights, in the event that automated decisions are taken, including profiling, you will have the right to obtain human intervention on the part of ECOEMBES and to express your point of view and challenge the decision.
6. Others: When personal data is transferred to a third country or to an international organisation, you will have the right to be informed about how you can access or obtain a copy of the appropriate safeguards relating to the transfer.

Likewise, you may lodge a complaint regarding the protection of your personal data with the Spanish Data Protection Agency at C/ Jorge Juan, 6, 28001 - Madrid, when the interested party considers that ECOEMBES has infringed the rights that are recognised by the applicable data protection regulations.

12. SECURITY MEASURES

ECOEMBES, in accordance with the applicable regulations, will always process the user’s data in the strictest confidence and will maintain the mandatory duty of secrecy regarding the same. For this purpose, ECOEMBES has adopted the necessary technical and organisational measures to guarantee the security of your data and prevent its alteration, loss, unauthorised processing, or access, considering the state of the technology, the nature of the data stored and the risks to which they are exposed, whether from human action or from the physical or natural environment.

13. ECOEMBES AS A SERVICE PROVIDER

In the cases in which, as an entity, company or Public Administration joins the SCRAP of ECOEMBALAJES ESPAÑA, S.A., we inform you that ECOEMBES will act as a data processor, as defined in the RGPD, being ECOEMBALAJES ESPAÑA, S.A. the data controller.

We inform you that the relationship between both parties is duly regulated by the data access agreement signed between both parties and in accordance with the requirements established in article 28 of the RGPD.

14. AMENDMENTS

ECOEMBES has the right to amend or modify its Privacy Policy at any time it deems appropriate, in which case users will be notified. For this reason, please check this privacy statement regularly to read the most recent version of the ECOEMBES Privacy Policy.

15. ACCEPTANCE AND CONSENT

The user declares to have been informed of the conditions on personal data protection, accepting the content of this Privacy Policy.

Last updated: December 2023.