1. Introduction
The purpose of this Policy is to inform, in accordance with applicable regulations, about the processing of personal data collected through the website https://www.encomenda.com/ (hereinafter, “Encomenda.com”).
Access to and use of Encomenda.com and/or its subdomains confer the status of user (hereinafter, “User(s)”) and imply knowledge and acceptance of all the conditions included in this Privacy Policy.
We are transparent about what we do with your personal data so that you understand the implications of the uses we make of it and the rights you have regarding your data. For this reason, we make all the information contained in this Privacy Policy permanently available to you, so that you may consult it whenever you deem appropriate.
2. Who is the Data Controller?
Identity: ENCOMENDA CAPITAL PARTNERS SGEIC, S.A. (hereinafter “ENCOMENDA”)
Tax ID (NIF): A66454448
Postal address: C/ Mèxic, 17 – 2º 1ª – 08004 Barcelona
Email: dpo@encomenda.com
3. How do we collect personal data?
Users are informed that, as a result of using certain functionalities of Encomenda.com, it may be necessary to provide certain personal data, which will be incorporated into files for which ENCOMENDA is responsible. Specifically, Encomenda.com will record the following information:
- Data from the contact form: the personal data voluntarily provided by the User interested in obtaining commercial information (name, surname, email address, and telephone number).
- Emails sent to ENCOMENDA: personal data (including, but not limited to, your email address) that the User provides when sending an email to any @encomenda.com address.
- Data from the funding request form: personal data, telephone number, email, and company information voluntarily provided by the User to participate in ENCOMENDA’s startup selection processes.
- Data from the registration form for events and activities organized by ENCOMENDA.
Please note that when we ask you to fill in your personal data to access a feature or service on the Website, certain fields will be marked as mandatory, as we need this data to provide the service or give you access to the requested functionality. If you choose not to provide such data, you may be unable to complete your registration or enjoy those services or features.
4. For what purposes do we process your data?
In general, the information collected through Encomenda.com and obtained from Users by ENCOMENDA will be processed for the following purposes:
a. To process and respond to requests made by Users through the forms available on Encomenda.com and/or by email.
b. To manage investment applications and, where appropriate, the selection process in which the User may be included.
c. ENCOMENDA processes the personal data collected at events for the purpose of managing, controlling, executing, and publicizing the event.
During events, photographs and video recordings may be taken in which your image may appear incidentally and may be published through ENCOMENDA’s communication channels, both print and digital, including Facebook, Twitter, LinkedIn, Instagram, and YouTube accounts, for the purpose of promoting the event.
d. ENCOMENDA may carry out monitoring and control activities on the use of the website in order to prevent and detect any fraudulent activity (such as technical manipulation, code modifications, etc.), and to prevent, avoid, and/or detect any unauthorized access, alteration, or loss of third-party information that could give rise to civil, criminal, and/or administrative liability for ENCOMENDA.
5. Are automated decisions or profiling carried out?
We inform you that there are no automated decisions, including profiling.
6. Who will your data be shared with?
ENCOMENDA does not intend to disclose your personal data to any third party.
To fulfill the purposes indicated in this Privacy Policy and properly manage the services provided and Users’ personal data, ENCOMENDA may engage third-party service providers who may have access to your data and will process it on behalf of ENCOMENDA as part of their service provision. ENCOMENDA undertakes to sign a corresponding data processing agreement with them, imposing, among others, the following obligations: to apply appropriate technical and organizational measures; to process personal data solely for the agreed purposes and in accordance with ENCOMENDA’s documented instructions; and to delete or return the data to ENCOMENDA once the service provision is completed.
No international data transfers are carried out.
7. What is the legal basis for processing your data?
The legal basis for processing the data collected is as follows:
- Legitimate interest: We consider that we have a legitimate interest in handling requests or inquiries made through the various contact channels, as processing this data also benefits you by enabling us to assist you appropriately and resolve your queries.
- Consent: We consider that we have the User’s consent when the candidate sends their contact and company information through Encomenda.com or by email to @encomenda.com addresses.
- Consent (events): The lawful basis for processing your data for registration in ENCOMENDA’s events and activities, as well as for photographing/recording such events, is the consent you provide.
- Legitimate interest (security): We rely on ENCOMENDA’s legitimate interest in ensuring the security of its website, systems, and information to process data for monitoring and control purposes.
8. How long will we keep your data?
The personal data collected will be kept by ENCOMENDA only for as long as necessary to handle and manage each specific request made by the User.
- For contact forms or email inquiries: for as long as necessary to properly address your request.
- For event and activity registrations: until the User withdraws the consent given.
- For funding request forms: for one year from the date the form was submitted.
After this period, the data may be blocked and retained by ENCOMENDA solely for the purpose of addressing any potential liabilities arising from processing, and only for the statute of limitations period of such liabilities. Once these periods have expired, the personal data will be deleted by ENCOMENDA.
9. What are your rights when you provide us with your data?
We are committed to respecting the confidentiality of your personal data and ensuring that you can exercise your rights. At ENCOMENDA, you can exercise your rights free of charge by sending an email to dpo@encomenda.com, simply stating the reason for your request and the right you wish to exercise. If we consider it necessary to verify your identity, we may ask you to provide a copy of a valid identification document. You may withdraw your consent to data processing at any time.
In particular, regardless of the purpose or legal basis under which we process your data, you may at any time request confirmation as to whether ENCOMENDA is processing your personal data, and if so, access such data. You may also request the correction of inaccurate data or request their deletion when, among other reasons, the data are no longer necessary for the purposes for which they were collected.
In certain circumstances, you may request the restriction of processing, in which case we will only retain your data for the exercise or defense of legal claims. You may also object to the processing of your data in specific situations. ENCOMENDA will stop processing the data unless there are compelling legitimate grounds or for the establishment or defense of claims. Finally, where applicable, you may exercise your right to data portability to obtain your data in an electronic format or have it transmitted to another entity.
To exercise these rights, please use the following channels, always attaching a copy of your ID card or another document proving your identity:
- By post: C/ Mèxic, 17 – 2º 1ª – 08004 Barcelona
- By email: dpo@encomenda.com
Lastly, you are informed that you may file a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos)—the competent supervisory authority in this matter—especially if you are not satisfied with the exercise of your rights, by writing to C/ Jorge Juan, No. 6, 28001 – Madrid, or via the website https://www.aepd.es.
10. Updates and changes to the Privacy Policy
ENCOMENDA reserves the right to make changes to this Privacy Policy, so Users are advised to review it periodically. When significant changes occur, Users will be informed and asked to accept them through notices on Encomenda.com or any other suitable means, depending on the circumstances.