Vinces Consulting, S.L., in compliance with personal data protection regulations, informs the user of this website (hereinafter, the “User“), contained in the page www.vincesconsulting.com (hereinafter referred to as the “Website“The following terms and conditions apply to the processing of your personal data in the context of your use of and interaction with the website, as well as to the processing of your data in the context of any contact you may have with Vinces Consulting.

Responsible for the processing of personal data

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

Vinces has an area dedicated to the attention and management of all issues related to data protection. For this purpose, the User may contact this area at 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.

Purpose 1: attention to communications, requests for information and resolution of queries.

• Data processed for this purpose: identification and contact data communicated through the means provided by Vinces, such as the form on the Web Site, by e-mail or by telephone. Specifically, and among other data that may be communicated depending on the specific query or communication that is transmitted, the processing of the name, surname, e-mail address, telephone number, professional position and company or entity in which the User works is foreseen.
• Description of the purpose: to answer the query and provide the information requested by the User.
• Basis of legitimacy: consent of the User by sending the form, on the understanding that the sending of the query constitutes a clear affirmative action for the processing of the data with the aim of resolving it.

Purpose 2:customer relationship management

• Data processed for this purpose: identification, contact and, where appropriate, financial, training and academic data, communicated through the means provided by Vinces, such as the form on the Web Site, by e-mail, by telephone, in the service provision contract or during the development of the relationship with Vinces. Specifically, and among other data that may be communicated, the processing of the name, surname, e-mail address, telephone number, professional position and company or entity in which the holder of the processed data works is envisaged.
• Description of the purpose: to manage, within the framework of the provision of its services, all aspects that may arise from the legal relationship established with Vinces.
• Basis of legitimacy: execution of the contractual relationship.

Purpose 3: data analytics through cookies

• Data processed for this purpose: depending on the case, identification, contact and navigation data may be processed. For example: browsing habits (browsing patterns, most requested functionalities and services, preferences, etc.) or browsing identifiers (browsing device or IP address).
• Description of the purpose: to analyse the User’s browsing on the Website in order to know the browsing patterns and thus improve the Website in those that are detected to be negative for the user’s experience and use of the Website.
• Basis of legitimacy: consent of the interested party, granted in accordance with the provisions of our cookies policy.

Purpose 4: sending own commercial 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.
• Basis of legitimacy: consent of the User (recipient of communications). The User may, at any time, withdraw the consent given by writing to privacidad@vincesconsulting.com.

Purpose 5: management of the reserved area of the Website

• 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.
• Basis of legitimacy: execution of the contractual relationship and provision of the requested service (access to the reserved area).

Purpose 6: Talent recruitment.

• 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.
• Basis of legitimisation: establishment of pre-contractual measures at the request of the data subject, with the intention of concluding a contract, within the framework of the selection processes in which the sender of the curriculum vitae participates.

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 the legitimate interest of Vinces, consisting of having identified, at all times, the significant representatives of the political, regulatory and social environments, in order to be able to carry out the aforementioned strategic consultancy work. Data subjects affected by this processing can (i) obtain further information about the processing of their data and (ii) exercise their right to object to the processing by contacting 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 foreseen. However, in the event of an international transfer, it shall be carried out in accordance with the criteria and requirements of the regulations in force, by means of the adoption of appropriate legal guarantees, which may consist of the formalisation with the recipient of the data of (i) Standard Contractual Clauses approved by the European Commission to legitimise international transfer of data to third countries or (ii) in another valid legal instrument which ensures an adequate level of protection equivalent to that of the European Economic Area.

User Rights

The User may exercise the rights of access, rectification or suppression, limitation of processing, opposition, portability, to oppose automated individual decisions and to withdraw the consent granted, by writing to Vinces at the following 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