Privacy Policy
Identity of the controller of the processing
- Company name: Talent First, S.L
- Trademark: Padula & Partners
- Tax Code: B-84107630
- Adress: Pz. del Niño Jesús 6; 1ºC, 28009 Madrid, Spain
- Tph: 913082130
- Email: seleccion@padulapartners.com
- URL: https://www.padulapartners.com/
- Registred: Registro Mercantil de Madrid tomo 20426, Folio 123, Hoja M-361292
According to the legislation on data protection, and any other relevant, current and applicable legislation, the user is informed that the personal data provided, so long as they proceed, will be incorporated into an automatic file which will be used for the purposes described in the form, contract, precontract or offer, as well as for sending information related to the activity of PADULA & PARTNERS.
Candidates data
In case you have provided your data to PADULA & PARTNERS as a potential candidate to be part of any of their selection process that, the company could have with any of their clients we inform you that PADULA & PARTNERS will use your data exclusively for these processes.
Besides, PADULA & PARTNERS will use your data among other possible processes that could come up.
PADULA & PARTNERS will contact you in case your profile could fit in any process in which you could accept or deny it. These data could be provided to the clients that hire the PADULA & PARTNERS services.
Your data will remain for a maximum period of 5 years. The legitimate basis is the consent provided by sending your personal data or curricula.
If you go throughout the entire selection process, PADULA & PARTNERS could demand data to people related to your previous work experience. If so, the candidate should inform the referenced people that the company that has selected him/her could only contact them in order to confirm the previous work experience.
The legitimate basis to the data treatment for this purpose is your consent in the moment of participating in the selection process, as well as the legitimate interest of PADULA & PARTNERS.
Data relating to clients, potential clients or suppliers
If you have provided your data as a contact person of a client, potential client or supplier of PADULA & PARTNERS, we inform you that PADULA & PARTNERS will use the data exclusively to maintain the contractual relationship and will not transfer it to third parties, unless data transfer is necessary to fulfil the contractual relationship with the data subject or your company. The data provided shall be retained while the contractual relationship is maintained or for the years necessary to fulfil the legal obligations. Furthermore, we inform you that as a client, potential client or supplier of PADULA & PARTNERS, PADULA & PARTNERS will be able to send you commercial information through the means that you have provided, including email, based on the Legitimate Interest regulated by the General Data Protection Regulation.
Furthermore, we inform you that PADULA & PARTNERS will be able to use your personal data for training and parameterisation purposes, when the service provided to the client requires it as such.
Contact and registration forms
The data of a personal nature, provided in the existing forms, will be used to solve the consultations proposed in the form itself and will not be transferred to third parties, unless your consultation requires such communication and exclusively with that aim.
The legitimate basis of the processing is your consent when filling out the form.
Furthermore, we inform you that that the personal data wil remain in PADULA & PARTNERS as long as you do not object to its processing.
As mentioned previously this data will be able to be use to send commercial information based on the intended legitimate interest.
Marketing and sending commercial information
We inform you that, PADULA & PARTNERS uses the contact data of client companies or potential clients to send information that may be of a commercial nature. To this end, the receivers of the information can be clients, potential clients with which PADULA & PARTNERS has previously had contact, persons who contact through the different PADULA & PARTNERS forms or that, through other means such as calls, visits or card exchanges, have shown interest in the services and products of PADULA & PARTNERS. In the case of a data subject receiving this type of information, it will be one of the scenarios listed. We understand that the information that PADULA & PARTNERS sends out can be of interest for the receiver and is at all times related to the products or services of PADULA & PARTNERS, and regarding which the subject has shown some sort of interest.
The legal basis for the lawfulness in the data processing with this aim is the legitimate interest of PADULA & PARTNERS. Said legitimate interest is intended to keep you informed at all times about the possibility of unsubscribing from this information being sent, since it is contact data of legal persons, for which reason the aim pursued by PADULA & PARTNERS will always be related to business, by sending information that is always related to the products and services of PADULA & PARTNERS, regarding which the holder is interested.
You can object to processing of the data with the noted aims at any time sending an email to seleccion@padulapartners.com
PADULA & PARTNERS does not communicate your data to third parties except when this is necessary to provide services, mediating data processor contracts which PADULA & PARTNERS has duly signed to do so. Said processors will be located outside the European Union. PADULA & PARTNERS will retain your data as long as the business or contractual relationship with you lasts, as long as you do not indicate to PADULA & PARTNERS that you wish not to receive commercial information.
Exercising of rights common to all personal data
The data subject has the right to obtain confirmation of whether in PADULA & PARTNERS we are processing their personal data, therefore, they have the right to access their personal data, modify inaccurate data or request the deletion thereof when the data is not necessary anymore, as well as object to the processing of their data for any aim explained herein such as sending commercial information.
You have the rights of access, modification, deletion, opposition, limitation of processing and portability which you will be able to exercise by
- email: dpo@padulapartners.com
- Paper mail Pz. del Niño Jesús 6; 1ºC; 28009 Madrid
- In any case, the data subject can go to the controlling authority corresponding to file the complaints they consider necessary. If located in Spain, this is the Spanish Data Protection Agency.
- Data Professional Officer: dpo@padulapartners.com
Truthfulness of data and updating
PADULA & PARTNERS assumes that the personal data provided through the different channels and supports is truthful, that the subject supplies it directly, that they are who they say they are, that the data is updated, that the affected/interested party will communicate any correction of their data from the time it is produced.
Duty of secrecy
The persons that intervene in the data processing concerning physical persons and access the files, directly or indirectly, will maintain secrecy at all times with respect to the personal data that they know in the development of the activity. The duty of secrecy consists of an obligation for PADULA & PARTNERS, the members of the management and supervisory bodies, the persons contracted under provisions of Labour Law; the professionals that offer contracted services under provisions of Commercial Law. This also implies an obligation for the suppliers of goods and services and their employees, the processors and their employees, who the processor subcontracts and their employees. The obligation of secrecy persists after the work or trade relationship established with PADULA & PARTNERS, controller, has ended, as well as after the expiration of the work, trade etc. contracts, which bind the employees and/or professionals to the Processor and the suppliers that supply goods or provide PADULA & PARTNERS services.
Data communication
We inform you that PADULA & PARTNERS could communicate client’s data in compliance of their legal obligations. Furthermore, as written PADULA & PARTNERS could communicate data related to candidates to PADULA & PARTNERS clients in case any selection process fits the candidate.
Duty of secrecy
The persons that intervene in the data processing concerning physical persons and access the files, directly or indirectly, will maintain secrecy at all times with respect to the personal data that they know in the development of the activity. The duty of secrecy consists of an obligation for PADULA & PARTNERS, the members of the managerial and supervisory bodies, the persons contracted under provisions of Labour Law, the professionals that offer contracted services under provisions of Commercial Law. This also implies an obligation for the suppliers of goods and services and their employees, the processors and their employees, who the processor subcontracts and their employees. The obligation of secrecy persists after the work or trade relationship established with PADULA & PARTNERS, controller, has ended, as well as after the expiration of the work, trade etc. contracts, which bind the employees and/or professionals to the Processor and the suppliers that supply goods or provide PADULA & PARTNERS services.
Treatment of the data by PADULA & PARTNERS as data processor
PADULA & PARTNERS shall be considered processor of personal data under the Client´s responsibility and instructions, only in case were PADULA & PARTNERS process personal data whose Controller is the Client for the fulfilment of the contractual relationship, as long as data is stored in PADULA & PARTNERS servers. PADULA & PARTNERS undertakes to:
- Use the personal data subject to processing, access or visualization, or those data that need to be gather, solely for the purpose of the assignment
- Process the data according to the Client´s instructions
- Keep a record of activities
- Maintain the duty of secrecy regarding all information, including data of personal nature that access have been granted under this agreement, even after the termination of the contract
- Ensure that the personnel authorized to process personal data are committed to respect the confidentiality and to comply with the corresponding security measures
- Guarantee the necessary training regarding the protection of personal data of the personnel authorized to process personal data
- Communicate to the Client the requests to the rights of access, rectification, deletion, opposition, limitation of the processing and data portability that the holders of the data may arise against PADULA & PARTNERS
- Notify the Client, without undue delay and through the email address indicated by the Client, of the security breaches aware and that may affect the personal data under the Client´s responsibility
- PADULA & PARTNERS will not communicate or allow the access of personal data under the Client´s responsibility to third parties, except in legally admissible cases or when subcontracting the provision or services is required to fulfil the contractual relationship with the Client. In this case, PADULA & PARTNERS shall sign the corresponding contract with the manager of the processing with the sub-manager, which shall contemplate the same conditions of this document
- Once concluded the provision of services that motivates the access, processing, visualization by PADULA & PARTNERS of data of personal nature under Client´s responsibility and, in any case, the termination of the contractual relationship, for any reason; PADULA & PARTNERS shall destroy or return the data to the Client. Nonetheless, PADULA & PARTNERS shall keep a copy with the data duly blocked, as long as responsibilities for the execution of the provision may be derived, only the exclusive effects of legal defence, internal audit and, for the purpose of compliance with the obligations that correspond by law
- Maintain the technical, operational and organizational security measures necessary to guarantee the confidentiality, integrity, availability and, permanent resilience of the processing of system and services PADULA & PARTNERS shall maintain sufficient security measures to comply with the provisions of Article 32 of Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data (“Regulation”)
- Comply with all obligations established in the Regulation.
Obligations of the Client in its condition of data controller
Client expressly declares with respect with the data provided to PADULA & PARTNERS:
- That they are adequate, pertinent and not excessive in relation with the determined, explicit and legitimate purpose for which they have been obtained.
- That such data is accurate and up- to-date.
- That the owners of such personal data have been informed of the creation and purpose of files, as well as the rights of access, rectification, deletion, limitation to processing, opposition, portability and claim, at their disposal.
- To deliver to PADULA & PARTNERS the data that, in the case, may be strictly necessary to the latter in order to provide the service entrusted under the Contract to which this document is attached.
- To comply with the obligations established in the Regulation.
Data security
PADULA & PARTNERS has implemented in its workplaces, facilities, systems, communications infrastructure, etc., the security means that the law on Data Protection of a personal nature requires. It has also adopted the logical, physical, organisational, contractual, etc. means that prevent access by third parties of the data without authorisation, the destruction, the correction, the reproduction, the disclosure, the transmission or the reuse thereof.
Recommendation of websites/pages
PADULA & PARTNERS, when it recommends or gives a link to any website/page considers that they are of interest to the user. PADULA & PARTNERS does not have an obligation of supervision with respect to the websites/pages of which it links to or recommends. They have been created by legal and physical persons or entities without legal personality that are separate from PADULA & PARTNERS. It does not intervene in their management, nor does it finance them, decide with respect to the incorporated content, not does it manage or participate in the services that the linked or recommended websites/pages supply. PADULA & PARTNERS will cancel any link by abstaining from recommending the website/page when it has credible proof that it and/or the services that it supplies are illicit or damage goods or rights of third parties susceptible to compensation.
Blog general use conditions
The users could use the Blog for the only purpose that it has been made, particularly, regarding the respect of the laws, moral and public order. Users, compromise to enter and use the Blog according to the next assumptions.
The User will not interfere in the proper functioning of the Blog or in the use that other Users are making of it; nor will it interfere or disturb the application or operation of the security measures implemented in the Blog or the connection to it of other Users or networks;
The User will comply with any rules that result from application to the access and use of the Blog, including those that affect the access, treatment and transmission of data;
The User will not use the Blog to send unsolicited emails or information or to promote or market, directly or through links, products or services of their own or of third parties, either free or onerously.
The User will not use the Blog to supplant the identity of a third party or impersonate another, nor to harass, insult or slander other people or perform acts of unfair competition or misleading advertising or not authorized by Spanish legislation or those present Terms of use.
The User will not use the Blog to collect information from third parties, in particular personal data.
The User may access, view, download, copy and print the comments, opinions, materials, data, information and, in general, any content contained in the Blog, as well as forward and share them with other people, exclusively for their personal use, that is, never with a commercial purpose. All the copies that you make of the comments, opinions, materials, data and information contained in the Blog must clearly identify their origin and authorship; and keep copyright notices or that refer to intellectual property rights, industrial or any other nature that originally included. The User will not use, reproduce, modify, distribute or make available to third parties the comments, opinions, materials, data or information contained in the Blog for commercial purposes or attribute their authorship or attribute it to whom does not apply. PADULA & PARTNERS, or the legitimate owner of the comments, opinions, materials, data or information downloaded, will continue to hold full ownership of them, as well as the brands and logos that may appear on them and on the Blog itself.
Contents Incorporated by Users and data protection.
The sending of contents will imply the full and unreserved acceptance of these Terms of Use and Privacy Policy, which will also regulate the use and exploitation of the same. PADULA & PARTNERS reserves the right to publish or not the articles and other content received, as well as the right to verify the data provided by the sender about their identity or to request, from the latter, that they prove the same.
In accordance with the data protection legislation the User consents that the personal data provided could be treated for the management of the blog. The legitimizing basis for the processing of data for this purpose is your consent to complete the corresponding form. The data will be kept as long as the user does not want to delete his comment. It has the rights indicated in this privacy policy.
Validity and correction of the privacy policy
The Privacy Policy established by PADULA & PARTNERS is in effect starting from the date of its publication on the corresponding website; the user can save and/or reproduce it. PADULA & PARTNERS is enabled to modify their Privacy Policy, making it known to the user.