Privacy policy
Privacy policy
Privacy policy
On this website, ATRINEO IBERIA processes users' personal data in a limited and transparent manner. In general, processing occurs through the use of analytics cookies and when users fill out the contact form to send inquiries, request information or quotes.
In accordance with current data protection regulations, Regulation 2016/679 (GDPR) and Organic Law 3/2018 on Personal Data Protection and Guarantee of Digital Rights (LOPDGDD), we inform our visitors and users -hereinafter, the data subject- of the following information:
1. Data controller
The owner of this website, and therefore legally responsible for data processing, is ATRINEO IBERIA, S.L., with address for notification purposes at Edificio Polivalente II – Parque Científico Tecnológico de la ULPGC, Planta 3, Oficinas 112-113 – Campus de Tafira, 35017, Las Palmas de Gran Canaria, Spain.
General contact email: info@atrineo.com
2. Purpose and legal basis for processing, and retention periods
2.1. Data obtained through the website
- Web visitors and users. If the data subject authorizes cookies, the IP address and browsing data will be processed to obtain website performance metrics and adjust content.
Legal basis: Data subject's consent, in accordance with Article 6.1.a GDPR.
Retention: Data collected by Google Analytics cookies will be deleted two years after the user's last visit.
- Quote requesters or similar. Considering the nature of our services and their target audience —universities, research centers and companies—, the personal data we process usually corresponds to contact persons of these entities. The purpose of processing is to attend to and manage requests for quotes, information or commercial offers; carry out follow-up of such offers by email, telephone or postal mail; and retain information for historical and consultation purposes.
Legal basis: Processing is legitimized, first, as pre-contractual measures, in accordance with Art. 6.1.b GDPR; and second, by the legitimate interest of ATRINEO IBERIA, regarding maintaining contact data of professionals and companies that request quotes, in accordance with Article 19 LOPDGDD, and Art. 6.1.f GDPR.
Retention: Data of data subjects, whether they are individuals or contact persons of a legal entity or similar, will be retained for the time required for civil liability, compliance with obligations to public administration, commercial, financial and tax matters, Art. 6.1.c GDPR. After the end of the contractual relationship, data will be retained in accordance with legal retention periods, which range from 4 to 10 years.
2.2. Other data processing
- Budgets. Purpose, legal basis and periods described in the previous section "Quote requesters or similar". The use of this data does not vary depending on the collection method (web or other means).
- Contracts. Processing of signatories' data for managing the contractual relationship established from the signing and provision of contracted services.
- Invoices. Invoice issuance and payment management.
Legal basis: Performance of a contract, Art. 6.1.b. GDPR; Compliance with ATRINEO IBERIA's commercial, tax and fiscal obligations, Art. 6.1.c. GDPR.
Retention: During the legal periods applicable at all times by civil, commercial and tax regulations. Art. 6.1.c GDPR.
- Email. Comprehensive management of contractual (clients and suppliers), pre-contractual (information or quote requesters) and organizational (contact agenda) relationships.
Legal basis: That related to the relationship with the data subject. Performance of a contract or application of pre-contractual measures, Art. 6.1.b.; contact agenda management, legitimate interest, Art. 6.1.f. and Art. 19 LOPD 3/2018.
Retention: During the legal periods in force regarding civil, commercial, administrative and tax liability of ATRINEO IBERIA (Art. 6.1.c GDPR); in case of contact persons, they will be maintained until the data subject requests their deletion.
- CV collection. Manage applications and evaluate profiles in current or future selection processes (when applicable).
Legal basis: Data subject's consent, Art. 6.1.a. GDPR.
Retention: Maximum 1 year.
- Authorization for image capture and publication. Capture images of the data subject or their representative, for subsequent publication on social networks, websites, and other media, for the purpose of disseminating ATRINEO IBERIA's activities and services.
Legal basis: Data subject's consent, Art. 6.1.a. GDPR.
Retention: During the following 5 years after capture. The user can request their deletion from social networks or ATRINEO IBERIA's website or project website in which ATRINEO IBERIA participates at any time.
- Registration for workshops, seminars and other events. Manage the registration request, as well as administrative and communication tasks related to it. Manage participation in the course or event, attendance, and delivery of certificates and other associated documents.
Legal basis: In the case of spontaneous requests, the affected party's consent, Art. 6.1.a. GDPR; in case of paid activities, performance of a contract, Art. 6.1.b. GDPR.
Retention: Data will be retained during the legal periods in force, regarding civil, commercial, administrative and tax liability of ATRINEO IBERIA (Art. 6.1.c GDPR).
3. Optional nature of the contact form and truthfulness of provided data
Our contact form is designed to streamline communication with website users. Mandatory fields are identified, which are essential to process your inquiry or request; if not completed, we will not be able to attend to it properly. We ask that you do not include confidential or sensitive information in the initial message. If it is necessary to expand data to manage your request, we will request it subsequently through an appropriate channel.
The person who submits the form or makes a quote or offer request guarantees that the data provided is truthful, accurate and up to date and commits to communicating any modification that occurs in them.
4. Communication of data to third parties
Personal data may be communicated to third parties in cases where the Law so provides. Some of the communication possibilities, depending on the purpose for which we process your data, are:
- To the German parent company Atrineo AG.
- To the competent Public Administration. In compliance with obligations imposed in fiscal, commercial, financial and tax matters.
- To State Security Forces and Corps, judges, prosecutors and courts, ombudsman, and other entities, organizations or bodies of the public administration.
5. Data subject rights
The exercise of the relative rights recognized by the GDPR is personal and non-transferable, the holder must prove their identity by means of a valid legal document, and complete the corresponding request form. Forms can be requested through the contact means made available to you by ATRINEO IBERIA or downloaded from the website of the Spanish Data Protection Agency (AEPD).
- Right to withdraw consent at any time. The data subject may revoke consents granted at any time, without this affecting the lawfulness of data processing during the previous effective period of such revocation.
- Rights of access, rectification and deletion. The data subject may request the exercise of their rights of access to data, rectification or deletion at any time, with the time limitations established in the GDPR.
- Rights to limitation or opposition of processing and data portability. These rights may be exercised in certain cases where, due to the nature of the data, processing, or contractual/pre-contractual relationship with ATRINEO IBERIA, the user may request their application.
You can exercise your rights before ATRINEO IBERIA by sending your request to «info@atrineo.com» or via certified letter to our address for notification purposes. Your request will be attended to within a period not exceeding 30 days. If upon receiving ATRINEO IBERIA's response, you consider that the exercise of your rights has not been properly attended to, you can file a complaint with the Spanish Data Protection Agency.
6. International data transfers
We inform you that, in general, international transfers of your personal data are not foreseen, with ATRINEO IBERIA adopting the necessary measures and guarantees in this area in accordance with current personal data protection regulations.
Notwithstanding the foregoing, our Cookie Policy informs about the use of Google Analytics. In this context, the use of social networks (in our case, LinkedIn) and third-party services (e.g., Google or Microsoft) involve international data transfers, as certain processing entails sending information to their servers, which may be located outside the European Union.
In these cases, ATRINEO IBERIA uses services from companies based in the U.S. provided they are certified under the EU-U.S. Data Privacy Framework.
7. Data security
ATRINEO IBERIA processes personal data in accordance with the principles of Article 5 of the GDPR (lawfulness, fairness, transparency, minimization, accuracy, limitation of retention and integrity and confidentiality) and has implemented appropriate technical and organizational measures, in accordance with a risk-based approach and privacy by design and by default criteria, to protect the confidentiality, integrity and availability of information. These measures include, among others, access controls and minimum privileges, communication encryption (e.g., HTTPS/TLS), password and authentication policies, access logging and traceability, backups and recovery procedures, vulnerability management and updates. Among the organizational measures adopted are the signing of NDAs by staff and collaborators with access to data, periodic privacy training and the duty of secrecy, valid during and after the professional relationship.
8. Changes and updates
ATRINEO IBERIA may update or modify this Privacy Policy to adapt it to legal changes or to the provision of its services. Any update will be published and communicated on the Website. Therefore, we recommend reviewing it periodically to learn how we protect your information.
