Vinces Consulting, S.L., in compliance with personal data protection regulations, hereby informs users of this website (hereinafter, the“User”), located at www.vincesconsulting.com (hereinafter, the“Website”), of the following terms and conditions, which will govern the processing of their personal data in connection with their use of and interaction with the Website, as well as the processing of their data in relation to any contact they may establish with Vinces Consulting.

Responsible for the processing of personal data

Vinces Consulting, S.L. ( hereinafter,“Vinces”), with its registered office at Calle de Fortuny 45, 28010, Madrid (Spain), and Tax Identification Number (NIF) B-85722106.

Vinces has a department dedicated to handling and managing all matters related to data protection. For this purpose, Users may contact this department at the following address:  privacidad@vincesconsulting.com

Purpose of data processing and basis for legitimisation

The User’s personal data will be processed by Vinces for the following purposes and on the following bases of legitimacy.

Objective 1: Handling communications, requests for information, and resolving inquiries

• Data processed for this purpose: identifying and contact information provided through the channels made available by Vinces, such as the form on the Website, by email, or by phone. Specifically, and in addition to any other data that may be provided depending on the specific inquiry or communication submitted, the following data will be processed: the User’s first name, last name, email address, phone number, professional title, and the company or organization where the User works.
• Purpose: To address the inquiry raised and provide the information requested by the User.
• Legal basis: the User’s consent by submitting the form, on the understanding that submitting the inquiry constitutes a clear affirmative action authorizing the processing of the data for the purpose of resolving the inquiry.

Objective 2: customer relationship management

• Data processed for this purpose: identification and contact information, and, where applicable, financial, educational, and academic information, provided through the channels made available by Vinces, such as the form on the Website, via email, by phone, in the service agreement, or during the course of the relationship with Vinces. Specifically, and among other data that may be provided, the processing of the first name, last name, email address, phone number, professional title, and the company or organization where the data subject works is anticipated.
• Purpose: To manage , within the framework of providing its services, all aspects that may arise from the legal relationship established with Vinces.
• Legal basis: performance of the contractual relationship.

Purpose 3: data analytics using cookies

• Data processed for this purpose: depending on the case, identifying, contact, and browsing data may be processed. For example: browsing habits (browsing patterns, most frequently requested features and services, preferences, etc.) or browsing identifiers (browsing device or IP address).
• Purpose: To analyze users’ browsing activity on the website in order to identify browsing patterns and thereby improve the website in areas where issues are detected that negatively impact the user experience and the use of the website.
• Legal basis: consent of the data subject, provided in accordance with our cookie policy.

Purpose 4: Sending our own marketing communications

• Data processed for this purpose: identification and contact data, such as name, surname and e-mail address.
• Description of the purpose: to send commercial communications related to the activity of Vinces.
• Legal basis: consent of the User (recipient of the communications). The User may withdraw their consent at any time by writing to  privacidad@vincesconsulting.com

Purpose 5: Management of the Website’s Members-Only Area

• Data processed for this purpose: identification, contact and professional data, such as name, surname, e-mail address, professional position and company or entity in which the User works.
• Description of the purpose: to grant and manage access to the reserved area of the Website.
• Legal basis: performance of the contractual relationship and provision of the requested service (access to the members-only area).

Objective 6: Attracting talent.

• Data processed for this purpose: identification, contact and professional data, such as name, surname, e-mail address, academic training and previous work experience.
• Description of the purpose: to manage the job applications that may be published at any given time, as well as to manage the database of CVs received by electronic means, for the purpose of studying the CVs and assessing new additions to the Vinces team.
• Legal basis: taking precontractual measures at the request of the data subject, with the intention of entering into a contract, as part of the selection processes in which the sender of the resume is participating.

Processing of professional location data

In addition to the above purposes, which are more related to the Users of the Website, Vinces also processes personal data related to individuals who have a professional relationship with relevant entities and bodies in the political, regulatory and social fields, such as ministries, political parties, public bodies and administrations, parliaments, professional associations, consumer associations or foundations.

The data processed are identification, contact and professional data, such as, for example, name and surname, e-mail address and contact telephone number, profession, professional career, and professional position currently held.

The purpose of the above data processing is to be able to professionally locate the interested parties (public, regulatory and social representatives), with the aim of contacting them on professional terms within the framework of the strategic consultancy work carried out by Vinces.

The processing is based on Vinces’ legitimate interest, which consists of identifying, at all times, key representatives from the political, regulatory, and social spheres, in order to carry out the aforementioned strategic consulting work. Data subjects affected by this processing may  (i) obtain more information about how your data is processed and (ii) exercise your right to object to the processing by contacting us at the following address privacidad@vincesconsulting.com.

Time limits for the retention of personal data

The personal data processed will be kept for the time necessary to fulfil the stated purpose in each case. For reference, the following retention periods can be noted:

• Resolution of queries, requests for information or attention to incidents: the data will be kept for the time required to resolve the doubt or question posed to Vinces, as well as for the time required to manage any incidents that may arise.
• Sending of commercial communications: the data will be kept for as long as the circumstance enabling the processing is maintained. That is: the User’s consent.
• Retention of CVs: CVs received may be retained for a period of 1 year after their last update, in anticipation of their usefulness in filling future vacancies in the Vinces team.

Recipients of personal data

Personal data, in line with the above-mentioned purposes, may be communicated:

1. To suppliers of Vinces, who will carry out their functions as data processors. The User (or any other interested party) may request information about the persons in charge that Vinces has at any given time for the development of its activity.
2. To Judges, Courts or Public Administrations to whom Vinces is obliged to communicate personal data of any User.

No international transfer of Users’ personal data is anticipated. However, should any international transfer take place, it will be carried out in accordance with the criteria and requirements established by current regulations, through the adoption of appropriate legal safeguards, which may consist of entering into an agreement with the recipient of the data regarding  (i) Standard Contractual Clauses approved by the European Commission to legitimize the international transfer of data to third countries, or (ii) in another valid legal instrument that ensures an adequate level of protection equivalent to that of the European Economic Area.

User Rights

The User may exercise the following rights with Vinces, where applicable, the rights of access, rectification, or erasure; restriction of processing; objection; data portability; the right to object to automated individual decision-making; and the right to withdraw consent, by sending a written request to the email address privacidad@vincesconsulting.com or to the registered office indicated above.

In addition, Users are informed of their right to lodge a complaint with the Spanish Data Protection Agency if they believe that their rights have been infringed.

Policy version: June 2021