Privacy Policy

1. Legal Regulations and Ownership

SINCRO ASESORES DE EMPRESA, S. L. P. U. (hereinafter, “SINCRO”), with Tax Identification Number (CIF) B84228386, will process your data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter GDPR), of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and Organic Law 3/2018, of December 5, 2018, on the Protection of Personal Data and Guarantee of Digital Rights.

2. Basic Information on Data Protection

3. Data Controller responsible for processing your personal data

4. Data processed

To provide the maximum possible detail regarding each data processing activity, they will be divided into different sections based on the various personal data processing activities. The purposes of these processing activities can be observed in detail in the following section.

The following information is collected and will be processed in accordance with the GDPR and LOPDGDD:

• For the purpose of managing job candidates for the organization, the following types of data are processed, which may be collected in paper format or via email:
• Identification data.
• Contact information.
• Academic data.
• Employment information.
• For the purpose of managing the organization's HR, the following types of data are processed, which may be collected in paper format or via email or the Platform designated for this use by the Data Controller:
• Identification data.
• Contact information.
• Academic and professional data.
• Bank details.
• To respond to inquiries from the data subjects (clients or potential clients), the following types of data are processed, which are collected through the website form or social media:
• Identification data.
• Contact information.
• Other data provided by the client and/or potential client.
• To manage suppliers and their invoicing, the following types of data are processed, which are collected through direct communication with the data subject (always in the case of individual suppliers, as data of legal entities is not covered by data protection regulations):
• Identification data.
• Contact information.
• Bank details.
• For sending commercial communications, the following data is processed:
• Identification data.
• Contact information.

5. Purpose of processing

At SINCRO, we use your personal data in accordance with the law for the following purposes:

• Management of job candidates for the organization.
• HR management, payroll and social security processing, vacation management, training management, and occupational risk prevention.
• Management of inquiries from data subjects and provide responses.
• Management of suppliers and necessary invoicing.
• Sending commercial communications.

Data collected through the website will not be used for automated decision-making.

No data from minors under 14 years of age is collected or processed.

6. Legal basis for data processing

The legal basis for processing your data is as follows, also separated by the processing activities shown in the previous section:

• The data processed for managing job candidates for the organization is based on the candidate's consent when submitting their CV, as established in Article 6.1.a) of the GDPR.
• The data processed for HR management is based on the performance of a contract to which the data subject is party, based on Article 6.1.b) of the GDPR.
• The legal basis for data processed to handle inquiries from interested parties is the legitimate interest of the interested party and their express consent, as established in Article 6.1.a) of the GDPR.
• The data processed for the purpose of managing suppliers and necessary invoicing with them is based on the contractual relationship between both companies, based on Article 6.1.b) of the GDPR.
• The data processed for the purpose of sending commercial communications will be processed based on the consent of the data subject, based on Article 6.1.a) of the GDPR.

7. Temporary limitation of data processing

Your personal data will be retained for the time necessary to fulfill the purpose of the processing, in accordance with the data retention policy of the General Data Protection Regulation 2016/679 and Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights, to comply with required legal obligations.

The data you have provided will be retained as long as it is necessary for the aforementioned purposes; it will also be stored for the period required by various applicable legislations.

If you wish to limit the period of time for which your personal data is processed, you must exercise your rights as indicated below.

Again, grouped by processing activity, the data retention period is as follows:

• The information processed for managing job candidates for the organization will be stored in our database to manage the selection process or future selection processes where the candidate's profile may be suitable.
• The information processed for HR management is stored until the termination of the employment relationship and for the period necessary to carry out the tasks required of the Data Controller by current regulations.
• The information processed for managing inquiries received and providing responses will be retained for the period necessary for the management, resolution, and subsequent follow-up of said inquiry.
• The information processed for supplier management will be stored until the contractual relationship between the parties ends, or until you exercise your rights stating that you do not wish SINCRO to continue processing your data.
• The data used for sending commercial communications will be stored until you withdraw your consent or exercise your rights mentioned below.

For more information about the personal data retention period, please consult the following table:

8. Recipients to whom your data is transferred

Your data will not be transferred to third parties, except by legal obligation. Specifically, it will be communicated to the State Tax Administration Agency and to banks and financial entities for the collection of the service provided or product acquired, as well as to the data processors necessary for the execution of the agreement.

In case of purchase or payment, if you choose any application, website, platform, bank card, or any other online service, your data will be transferred to that platform or processed in its environment, always with maximum security.

When we instruct them to do so, the web development and maintenance company, or the hosting company, will have access to our website. These companies will have signed a service provision contract that requires them to maintain the same level of privacy as us.

The foregoing is without prejudice to what is indicated in the Cookie Policy regarding international transfers that, where applicable, may be carried out as a consequence of a legal obligation.

9. Data confidentiality and security

SINCRO is committed to using and processing users' personal data, respecting their confidentiality and using them in accordance with their purpose, as well as to comply with its obligation to store them and implement all measures to prevent unauthorized alteration, loss, processing, or access, in accordance with the provisions of current data protection regulations.

SINCRO has adopted the necessary technical and organizational measures available to it according to the state of the art to guarantee the security and integrity of the data, but SINCRO cannot guarantee absolute prevention of data breach through fraudulent access by third parties.

10. Rights in the processing of your data

You have the right to obtain confirmation as to whether or not personal data concerning you are being processed by SINCRO.

You, as the data subject, have the right to access your personal data, as well as to request the rectification of inaccurate data or, where appropriate, to request its erasure when, among other reasons, the data are no longer necessary for the purposes for which they were collected.

We remind you that you have the right to withdraw your consent at any time, which implies withdrawing the data that the company holds about you. To do so, you must send an email to [email protected] providing your National Identity card (DNI), or send it by postal mail to the address indicated above.

In certain circumstances, you may request the restriction of the processing of your data, in which case we will only keep it for the exercise or defense of claims.

We hereby inform you that you may object to the processing of your data at any time. In that case, we will cease to process the data, except for compelling legitimate grounds, or the exercise or defense of possible claims.

You will have the right to data portability, i.e., to have the personal data you have provided transferred directly to another controller in a structured, commonly used, and machine-readable format, when technically feasible.

To exercise the rights mentioned above or to make any claim about how we have processed your personal data, send an email to [email protected]

If you still consider that your personal data has not been processed appropriately in accordance with the law, you may lodge a complaint with the relevant data protection authority, with the Spanish Data Protection Agency being the indicated one for Spanish territory, located at C/ Jorge Juan, 6. 28001 – Madrid.

11. Acceptance and consent

You declare that you have been informed of the conditions regarding the protection of personal data, accepting and consenting to their processing by SINCRO in the manner and for the purposes indicated in this privacy policy, based on the processing you are taking part in.

SINCRO reserves the right to modify this policy to adapt it to legislative or jurisprudential changes, as well as to industry practices. In such cases, SINCRO will announce the changes introduced on its website with reasonable notice before their implementation.