BASIC INFORMATION ON PERSONAL DATA PROTECTION
Who is the data controller?
What do we use personal data for and what is the basis of legitimacy?
Execution of the contract: To provide services, manage payment, contact the client.
Consent: To answer queries, marketing.
Legitimate interest: Send commercial information.
Legal obligation: Interested parties' requests.
What data will we process?
Recipients of personal data
Ancillary services are contracted with service providers who, as processors, will have undertaken to comply with the applicable data protection regulations at the time of contracting.
When and how do we get the data?
We collect information about you when you request information through web forms or use the Remember Me Space.
What rights can you exercise?
You have the right to access, rectify or delete your personal data. In some cases, you also have other rights, for example, to object to our use of or portability of your data.
ELYSIUS EUROPA, S.L., with its trademark ALTIMA SERVEIS FUNERARIS INTEGRALS (hereinafter, ALTIMA) respects the current legislation on personal data protection, the privacy of users and the secrecy and security of data in accordance with the provisions of the applicable legislation on data protection, and applies appropriate technical and organisational measures in order to ensure and demonstrate that the processing of data for which ALTIMA is responsible complies with the aforementioned regulations.
1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR DATA?
The party responsible for the processing of personal data is ELYSIUS EUROPA, S.L. (hereinafter, ALTIMA), with registered office at C/Saragossa, nº 6, 08830, Sant Boi de Llobregat (Barcelona) and NIF B-63230759. Email: firstname.lastname@example.org.
2. WHAT PERSONAL DATA WILL WE PROCESS?
ALTIMA only processes the personal data that are relevant for the purposes mentioned in Section 4 below. Specifically, it processes the following categories of personal data of the data subject (indicative, non-exhaustive list), regardless of the legitimacy of the processing and whether the data are obtained from third party sources or directly from the data subject:
- Identification data: name, surname and identity/passport number.
- Contact details: e-mail address, postal address and telephone number.
- Financial and bank details, necessary for the correct provision of the service.
- Contracted service data. These data are necessary for the correct provision of the service.
- Other data provided voluntarily by the interested party or third party when contacting us for any reason (making a complaint or query, etc.) and providing a response. If you are a customer, they will be included in the contract file and will be used for the correct provision of the service (contact details of a third party for notifications, details of third parties who are authorised by the customer to carry out various formalities on their behalf in relation to their contract).
- Academic and professional data: training/qualifications, professional experience, and all those data that are incorporated in the CV, in the case of selection processes.
- Browsing history data: IP address, web pages visited and country from which the connection is made.
In general, personal data of minors will only be processed when their parents or legal guardians have given their consent for the processing that is necessary for the execution of the corresponding contract/service, the fulfilment of a legal obligation and/or in our legitimate interest.
3. WHEN AND HOW DO WE OBTAIN THE DATA?
The provision of personal data through the forms on the website is completely voluntary, although failure to provide certain data may make it impossible to obtain a response.
Similarly, there will be personal data required for the provision of contracted services that it will be essential to provide, in which case we will inform of the mandatory and/or necessary nature of providing personal data for the operation of the service.
In this sense, the concept of "client" includes any interested party who has the status of: declarant, contracting party, deceased, designated, relatives of the deceased or rightful claimant, who establishes a contractual or service relationship. In the event that personal data is provided by a person other than the data subject, the data provider is obliged to provide this information to the data subject in advance and to obtain the consent of the data subject where necessary for processing by us.
4. WHAT DO WE USE PERSONAL DATA FOR AND WHAT IS THE BASIS OF LEGITIMACY?
We use personal data for the following purposes and with the following legitimate basis as the case may be:
To execute and maintain the existing contractual relationship between ÁLTIMA and the interested parties, including the communication to the financial institutions of the personal data strictly necessary to make the agreed payments.
This purpose includes the processing of your data for, mainly:
Execution of a contract (art. 6.1.b) RGPD):
Refusal to provide the personal data requested by ÁLTIMA could result in the impossibility of concluding or maintaining said contract.
Attention to queries and requests made by users or potential customers. They will be processed for the purpose of managing or resolving the query, request or application made.
Marketing. Personal data will be processed to manage the sending of information, advertising and commercial promotion of products, services and activities of interest related to funeral services, including by electronic means (e-mail or SMS).
On the other hand, non-registered users may also interact with the site to post comments or condolence notes. We will process the personal data, if you authorise us to do so, for the management of the publication. The comment may also be published anonymously if requested.
Consent (art. 6.1.a) GDPR):
Data subjects may grant their consent through data collection forms, by clicking on acceptance buttons or ticking boxes, replying to emails or taking any other clear affirmative action.
Data subjects may revoke their consent at any time, as detailed in Section 8. In any case, the withdrawal of consent will not affect the lawfulness of the processing previously carried out.
Legitimate Interest of ÁLTIMA and/or Third Parties (Art. 6.1.f) GDPR):
ÁLTIMA considers that the legitimate interest on which it bases the processing of personal data prevails over the fundamental rights and freedoms of the data subjects. We also understand, on the other hand, that our customers can reasonably expect their personal information to be processed for these purposes, as the processing:
In any case, data subjects can request more information regarding the legitimate interest or exercise their right to object by sending such a request to email@example.com.
To attend to the requests of the interested or affected parties in the exercise of the rights established in the RGPD.
Legal obligation (art. 6.1.c) RGPD)
ALTIMA needs to process the personal data requested in order to comply with legal obligations.
5. HOW LONG DO WE KEEP THE DATA?
Data derived from the execution of a contract will be kept for as long as the contractual relationship that we have established is maintained, in order to manage it properly. Once this relationship has ended, we must keep the data duly blocked for an additional period during which there may be any legal liabilities arising from services provided or processing carried out.
Personal data provided for purposes other than the contractual relationship, such as queries, participation in the Space for Remembrance, etc., will be kept for the time necessary to process your request, plus an additional period for the purpose of meeting any legal liabilities arising from the same.
If you have authorised us to send you commercial communications, we will keep your data until you tell us that you no longer wish to receive offers, even if the contractual relationship with us has ended.
Candidate data will be retained for a period of two years from receipt of the CV, after which time it will be automatically destroyed.
For compliance with legal obligations and the formulation, exercise and defence of claims, once the authorisations to use your data have been revoked by withdrawing your consent, or the contractual or business relations you have established with us have ended, we will only keep your data to comply with legal obligations and to allow the formulation, exercise or defence of claims during the limitation period of the actions arising from the contractual relations.
We will process this data by applying the necessary technical and organisational measures to ensure that it is only used for these purposes.
We will destroy your data when the retention periods imposed by the regulations governing ÁLTIMA's activity and the statute of limitations for administrative or legal actions arising from the established relationships have elapsed.
6. RECIPIENTS OF PERSONAL DATA
We also specifically inform you that the Entities of the Áltima Group share, with varying degrees of integration, common IT services and accounting, personnel management and payroll services, among others, in order to take advantage of existing synergies, optimise resources and offer a better service to customers.
(ii) Other Entities: Personal data may also be communicated to other companies related to funeral services, such as insurers or mutual insurance companies, collaborators and service providers, such as, but not limited to: cemeteries, undertakers, marble workers, press or any other physical or digital means of communication of obituaries, experts, lawyers, auditors, consultants, specialists in administrative procedures, financial institutions, and other suppliers and professionals, who will process the personal data as data processors in the name and on behalf of the data controller, in order to guarantee the services provided by said data controller in the execution of the contract or service, comply with the obligations derived from the applicable regulations, in legitimate interest and/or in accordance with the consent provided where applicable.
ÁLTIMA follows strict criteria for the selection of service providers in order to comply with its data protection obligations and undertakes to sign the corresponding data processing contract with them, imposing on them, among others, the following obligations: to apply appropriate technical and organisational measures; to process personal data for the agreed purposes and only in accordance with ÁLTIMA's documented instructions; and to delete or return the data to ÁLTIMA once the provision of services has been completed.
(iii) Official Bodies and Authorities: Personal data will be provided to all those recipients to whom it is obliged to communicate such information in compliance with legal obligations, including, but not limited to: competent Public Bodies and Administrations, such as the Spanish Tax Administration Agency or the Regional Tax Authorities, the personal data protection control authorities, Health and Environmental Control Authorities, the Courts and Tribunals, the Public Prosecutor and/or the State Security Forces and Corps. As well as Customs and the agency responsible for dealing with Customs when a deceased person is transferred to a non-EU country.
7. INTERNATIONAL DATA TRANSFERS OUTSIDE THE EEA
At ALTIMA we process your data within the European Economic Area and, as a general rule, we engage service providers who are also located within the European Economic Area (EEA) or in countries that have been declared to have an adequate level of protection.
However, when a family requests the transfer of a deceased person to a country outside the EEA. In such a case, we will provide the details of the deceased and the family representative to the competent public authorities and bodies in accordance with the relevant official procedures and regulations in each country. In order to safeguard personal data, the security measures set out in the GDPR and the Data Protection Act are applied, in addition to the data protection regulations of the destination country.
If, apart from the above, we need to use service providers that carry out processing outside the EEA or in countries that have not been declared with an adequate level of protection, we will ensure that we guarantee the security and legitimacy of the data processing.
8. WHAT RIGHTS CAN YOU EXERCISE AND HOW?
The regulations recognise the following data protection rights, which are applicable to all data subjects:
You have the right to obtain confirmation from ALTIMA as to whether or not personal data concerning you are being processed, as well as the right to access the personal data held by ALTIMA.
You may modify your personal data if it is inaccurate or incomplete.
You may request that we delete personal data concerning you when, among other reasons, the data is no longer necessary for the purpose for which it was collected.
You may request that we do not process your personal data when it is processed on the basis of public or legitimate interest. ALTIMA will stop processing the data, except for compelling legitimate reasons or for the exercise/defence of possible claims.
You may request the limitation of the processing of your data in the following cases: (i) While the contestability of the accuracy of your data is being checked; (ii)Where the processing is unlawful, but the data subject objects to the erasure of your data; (iii) Where ALTIMA does not need to process your data, but the data subject needs it for the exercise or defence of claims; (iv) Where the data subject has objected to the processing of your data for the performance of a task carried out in the public interest or for the satisfaction of a legitimate interest, while verifying whether the legitimate grounds for the processing override your legitimate grounds for the processing.
Receive in a structured, commonly used and machine-readable format the personal data provided, as well as transmit them to another controller where the processing is based on consent or a contract and is carried out by automated means.
Submitting a complaint
In any case, as the data subject, you have the right to lodge a complaint with the Spanish Data Protection Agency.
The user may exercise the aforementioned rights through the following postal address: C/ Saragossa, 6, 08830 - Sant Boi de Llobregat (Barcelona) to ATT. DEPARTMENT RESPONSIBLE FOR RGPD. Communication made by the user to the following e-mail address will also be valid: firstname.lastname@example.org. In both cases, a photocopy of the ID card or equivalent document that accredits identity and is considered valid in law must be provided. In the event of acting through legal representation, the ID card of the representative and a document accrediting representation must also be provided.
9. IS THE PERSONAL DATA SECURE?
ÁLTIMA assures the confidentiality of your personal data and guarantees its security, adopting the necessary measures to avoid its alteration, loss, treatment or unauthorised access.