Update: 07-03-2022
In order to receive and process your report, you must confirm that you have read this Complaints Channel Data Protection and Privacy Notice. If you do not agree to the terms and conditions in accordance with the notice, you will not be able to make the complaint.
Remember that this channel is not intended to communicate emergencies.
The complaints channel is managed by ESKARIAM ADVISORS, S.L (hereinafter ESKARIAM), using the “ithikios” platform, of which Digital Products Development, S.L. is the owner, a company specialised in offering internal complaints channel management systems for companies. It maintains a contractual relationship with ESKARIAM as the data sub-processor for the purpose of receiving, storing and sending communications to the ESKARIAM Compliance Team. Ithikios guarantees the security and confidentiality for the purpose of the processing contracted.
Below is the information on how we process your personal data for the Complaints Channel:
| Data controller |
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Data Protection Officer | For anything related with the processing of personal data by ESKARIAM please contact our Data Protection Officer at the following email address: [email protected] |
Data subject to processing and source | These will be your contact:
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Purpose of processing and Legitimation | In accordance with regulations in force on data protection, ESKARIAM wishes to inform you that your personal data shall be collected and processed with the purpose of:
It is our legitimate interest to ensure compliance with applicable policies and rules and/or legislation.egislation. |
Assignment Recipients | Data may be communicated to any third parties to which ESKARIAM is legally obliged to provide them if this is necessary or required, such as Public Bodies, Judges and Courts. Third-party professionals who may use ESKARIAM to perform all or part of the instruction and investigation of complaints that arise may also have access to such data, professionals who will be subject to a duty of secrecy, reservation and confidentiality at all times during their work. |
| International transfer recipient | Any arising from the processing of the complaint, issue or concern to any other company from the group, as well as any arising from our relationship with the provider that manages the Complaints Channel with the guarantees that are included in the Privacy Policy |
Rights of the data subjects | Data subjects can exercise their rights of access, rectification, deletion and portability of their data, of restriction of and opposition to their processing, as well as not being subject to decisions based solely on the automated processing of their data, when appropriate, to ESKARIAM for the facts communicated the addresses of which have been identified above. We also wish to inform you that you can make a complaint to the Spanish Data Protection Agency, in the event that you believe that your data has not been processed in an appropriate manner (www.aepd.es) |
| Data storage | Personal data shall be kept in accordance with the provisions of applicable law. In particular, data shall be kept in the channel only for the time necessary to decide on the appropriateness of an investigation into the facts communicated, which may be prolonged for a maximum of three (3) months from the date of the registration of the communication/complaint. In any case, all these data must be deleted from the system once this time has elapsed, unless the purpose of the retention is to leave evidence of the operation of the channel, in which case they will be anonymised. However, in the event that it is necessary to process personal data for a longer period of time to continue the investigation or because a decision has been made to take legal action, the data will be retained in an environment other than the Ethical//Complaints Channel to the extent necessary for the conclusion of the investigation or for the exercise of actions by ESKARIAM in the corresponding judicial proceedings. Communications/complaints that have not been dealt with will only be recorded in the system anonymously, but will not be blocked. |
Complete ESKARIAM Privacy Policy: https://eskariam.com/politica-de-privacidad/