Privacy policy

In accordance with General Data Protection Regulation (EU) 2016/679, and complementary data protection legislation, through this Privacy Policy, the user is informed of the following sections:

 

  1. Who is the Data Controller?
  • Data Controller: Temprano Capital, S.L. (hereinafter, “TEMPRANO CAPITAL”).
  • Registered Office: Calle Poeta Joan Maragall, 1, 7º, Madrid, Spain.
  • Tax Identification Number: B-86650777.
  • Phone: +34 917 378 878.
  • Contact details of the Data Protection Officer (DPO): dpo@tempranocp.com.

TEMPRANO CAPITAL is the data controller of the personal data provided by the users (hereinafter referred to as «user» or «data subject») through the website www.tempranocp.com (hereinafter referred to as the «Website»).

 

  1. ​Information and consent

By accepting this Privacy Policy, which is written in clear, concise and transparent language, the user is informed and gives their free, informed, specific and unequivocal consent for the personal data they provide through the Website will be processed by the Data Controller, as well as and any other data you may provide to the Data Controller within the future.

 

  1. Obligation to provide data

The data requested in the forms on the Website are, in general, mandatory (unless otherwise specified in the required field) in order to fulfill the established purposes.

Therefore, if they are not provided or are not provided correctly, these requests cannot be met, without prejudice to the fact that you may freely display the content of the Website.

 

  1. For what purposes will we process your personal data?

The Data Controller will process the personal data of the users for the following purposes:

  1. To manage queries, doubts or requests made by users through the contact form made available to them through the Website
  2. To evaluate the user’s candidacy for open selection processes published on the Website.
  3. To deal with your requests to exercise your data protection rights.

 

  1. What category of data do we process?

In accordance with the above-mentioned purposes and depending on the contact method selected by the user to contact TEMPRANO CAPITAL, the following categories of data will be processed by the Data Controller:

  • Identification data: name, surname.
  • Contact details: e-mail, telephone.
  • Academic and professional data: education and history of the user.
  • Employment details: position and company of the user.

In the event that the user provides data from a third party, he or she states that he or she has the consent of the third party to communicate them to the Data Controller and undertakes to pass on the information contained in this Privacy Policy, exempting the Data Controller from any liability in this regard. However, the Data Controller may carry out periodic checks to verify this fact, adopting the corresponding due diligence measures, in accordance with data protection regulations.

 

  1. What is the lawful basis for the processing of your personal data?

The legitimacy of the processing of your personal data will be the following:

  1. Data provided in the contact form: the lawful basis is the consent given by the user, which may be withdrawn at any time, by the means made available to him/her.
  2. Data provided through the sending of job applications: the lawful basis of the processing of such data is the consent of the user, consent that may be withdrawn at any time, through the means made available to users.
  3. Data provided for the exercise of rights: the lawful basis of the processing of such data is the legal obligation of the Data Controller to manage such rights in accordance with the applicable regulations.

The consents obtained for the aforementioned purposes are independent and the user may withdraw only one of them without affecting the others.

 

  1. How long do we store your personal data?

The Data Controller will store users’ personal data only for the time necessary to carry out the purposes for which they were collected, as long as the consent granted is not withdrawn. Subsequently, if necessary, the Data Controller will keep the information blocked until the legal liabilities that may have arisen as a result of the processing of the users’ personal data have expired, at which time the data will be irreversibly erased.

  1. The data provided in the contact form will be stored for the period necessary to process and reply to your request and once completed, during the period of limitation of legal actions derived from the aforementioned request.
  2. The data provided through the sending of job applications will be stored for a period of one year from receipt of the CV, unless the user gives his/her consent again to keep the CV information.
  3. The data provided for the exercise of rights will be stored for the period necessary to manage and process the rights exercised and, once this period has ended, for the limitation period of the legal actions that may arise from the request, in accordance with Article 78 of Organic Law 3/2018, of December 5, on Personal Data Protection and Guarantee of Digital Rights.

 

  1. What security measures do we apply?

In order to safeguard the security of your personal data, we inform you that the Data Controller has taken all necessary technical and organisational measures to ensure the security of the personal data provided. All of this is to avoid their alteration, loss, and/or unauthorized processing or access, as required by the regulations, although absolute security does not exist.

Likewise, the Data Controller informs you that all our personnel, whatever the phase of the processing in which they intervene, have adopted the commitment to process your personal data with the utmost care, secrecy and confidentiality and that their processing will be carried out in accordance with the data protection legislation.

 

  1. Which recipients will personal data be communicated to?

The personal data provided will not be communicated to third parties unless a legal requirement from Public Administrations or – Law Enforcement Forces and Agents obliges the Data Controller to do so.

The Data Controller has the collaboration of third -party service providers who may have access to your personal data and who will process the data on behalf of, and for the account of, the Data Controller, as a consequence of their services.

In this respect, the Data Controller follows strict criteria for the selection of service providers in order to comply with its data protection obligations and undertakes to enter into a data processing agreement, whereby it will impose on them, inter alia, the following obligations: to apply appropriate technical and organisational measures to ensure security of personal data; to process personal data for the agreed purposes and in accordance only with the documented instructions of the Data Controller; and to delete and return the data to the Data Controller upon completion of the services.

 

  1. What rights does the user have in data protection?

In accordance with data protection legislation, the user has the right to:

  • To withdraw his or her consent at any time, without prejudice to the lawfulness of the processing previously carried out.
  • To access to personal data and obtain confirmation as to whether the Data Controller is processing personal data concerning the user
  • To rectify inaccurate or incomplete personal data.
  • Request the erasure of his or her personal data when such are no longer necessary for the purposes for which they were collected, among other reasons.
  • To restrict the processing of personal data whenever any of the conditions of the data protection regulations are met.
  • Request the portability of personal data in those cases provided for in the regulations.
  • Object to the processing of personal data, where appropriate.

In order to exercise the above rights, the user must send a request to the address indicated in the header of this document or through the e-mail address of the Data Protection Officer at dpo@tempranocp.com.

The user is informed that the person in charge will respond to the right exercised within one month, counting from the reception of the request. This period may be extended by two months, considering the complexity and number of applications, and in any case the user must be notified in order to inform him/her of this.

Finally, the user may, additionally, file a complaint with the Spanish Data Protection Authority or the competent supervisory authority if he or she considers that the Data Controller has violated his or her data protection rights.

 

  1. User liabilty

The Data Controller will store users’ personal data only for the time necessary to carry out the purposes for which they were collected, as long as the consent granted is not withdrawn. Subsequently, if necessary, the Data Controller will keep the information blocked until the legal liabilities that may have arisen as a result of the processing of the users’ personal data have expired, at which time the data will be irreversibly erased.

  1. Guarantees that he/she is over sixteen (16) years old and that the information you provide to the Data Controller is true, accurate, complete and up to date. For these purposes, the user is responsible for the veracity of all the data provided and will keep the information provided suitably updated, so that it corresponds to his/her real situation.
  2. Guarantees that he/she has informed the third parties from whom he/she provides his/her data, if he/she does so, of the aspects contained in this document. He/she also guarantees that he/she has obtained their authorization to provide their data to the Data Controller for the aforementioned purposes.
  3. He / she will be liable for any false or inaccurate information he/she provides through the Website and for any damages, direct or indirect, caused to the Data Controller or third parties.

Last updated: September, 2021.