ENCOMENDA CAPITAL PARTNERS SGEIC, S.A. undertakes to comply with the personal data protection legislation in force, as set out in Regulation (EU) 2016/679 of the European Parliament, Organic Law 3/2018 of 5 December on Personal Data Protection and Guarantee of Digital Rights, and any other national laws and regulations that complement and develop it.
Please take a moment to review the key aspects of our privacy policy, as you must accept them to continue using this service.
For what purpose do we process your data?
This is a confidential communication channel for clients, employees, and other stakeholders linked to ENCOMENDA CAPITAL PARTNERS SGEIC, S.A.
Its aim is to provide a prompt and appropriate response to any doubt, discrepancy, or irregularity regarding compliance with the legislation in force, our Code of Ethics, corporate policies, procedures, internal rules, and voluntarily assumed commitments. It enables the investigation of reported facts and, where appropriate, proposes the relevant corrective measures.
How long will we keep your data?
The information provided will be kept for 3 months from the time the case is resolved or, where applicable, for the period legally established.
If it is necessary to retain the information to continue the investigation, it may continue to be processed in a separate environment by the body within the entity responsible for the investigation.
What is the legal basis for processing personal data?
The legal basis for processing personal data is, in some cases, the existence of a public interest in preventing and addressing infringements of applicable law and, in other cases, the contractual relationship or the legitimate interest that ENCOMENDA CAPITAL PARTNERS SGEIC, S.A. has in pursuing and preventing actions that contravene the corporate policies and ethical standards of ENCOMENDA CAPITAL PARTNERS SGEIC, S.A.
Who will your data be shared with?
Personal data will be used solely for the purpose stated in the “contacto Canal Denuncia” form, and only those performing compliance functions at ENCOMENDA CAPITAL PARTNERS SGEIC, S.A. will have access to the information submitted.
ENCOMENDA CAPITAL PARTNERS SGEIC, S.A. will not disclose or transfer personal data to third parties, except where there is a legal obligation, in which case your information will be available to Public Administrations, Judges, and Courts for the handling of any potential liabilities.
Who will have access to the data?
Access to the data contained in these systems is strictly limited to those who carry out internal control and compliance functions, or to any data processors that may be designated for this purpose.
However, access by other persons—or even disclosure to third parties—will be lawful where necessary for the adoption of disciplinary measures or for the handling of legal proceedings, where applicable. The data may also be disclosed to the relevant persons involved in any subsequent investigation, under the terms permitted by current legislation and for the purposes described above.
What are your rights?
Users may exercise their rights of access, objection, rectification, and erasure at any time, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council.
In certain circumstances, the data subject may request the restriction of processing, in which case the Whistleblowing Channel will retain the data only for the exercise or defense of claims.
The data subject has the right to receive the data concerning them and to request the portability of their data to another data controller, where technically feasible, in a structured, commonly used, and machine-readable format.
To exercise these rights, in accordance with current legislation, data subjects may use the email address dpo@encomenda.com, attaching a copy of an identification document (National ID or Passport) and expressly indicating the right they are exercising.
The data subject may lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos), especially when they are not satisfied with the exercise of their rights. For more details, please consult the website https://www.agdp.es.