In compliance with the provisions of Regulation (EU) 2016/679, of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data ("GDPR"), and with Spanish Organic Law 3/2018, of 5 December, on data protection and digital rights ("LOPDGDD"), and other related regulation, with this Privacy Policy we aim to provide information on how we process the personal data we collect via emails or any and other contact channels made available to you on this website ("Website").
Except otherwise stated in a particular clause on the Website or in an information clause provided prior to the processing being carried out, the provisions of this Privacy Policy shall apply.
Please note that for some data processing purposes we may need to request and receive your express consent (see the "Data processing purposes" section in this Privacy Policy). However, for other purposes laid out in the section, we are not required by law to obtain your express consent and you should therefore be aware that, when engaging in the activities for which consent is not required, the provisions in the Policy regulating said purposes shall be deemed accepted by you.
Refusal to provide the mandatory or necessary personal information will prevent the fulfilment of the services requested, as long as the information is required by law or needed to execute a contract with you.
Unless specifically stated otherwise at the time of its collection, the personal data requested through our Website or other channels is mandatory or necessary for providing the service for which the data is processed.
In any case, you guarantee and are accountable for the accuracy, validity, and authenticity of the personal data you provide and commit to keeping duly updated.
Impulsa Capital, S.L. (“Impulsa”)
Contact for data protection purposes:
We may process your data in accordance with the following legal grounds:
Consent
If you give your consent, we will perform the processing operations in relation to the extent of your consent and for the reported purposes.
You may withdraw your consent at any time.
Contract execution
We are allowed by law to process your data when necessary for the execution of a contract (commercial, employment, or administrative) to which you are a party or for the implementation of pre-contractual measures, in order to provide our products and services and fulfil the obligations set forth in the contract.
Legal duty
We may have to process personal data because we are required to do so by law, for example for invoicing purposes, accounting processes, tax reporting, or the prevention of money laundering.
Legitimate interest
We may process your personal data for the purposes of “legitimate interest,” i.e., for processing operations we perform as data controller.
Public interest
Occasionally, we may need to process your data for tasks performed in the public interest or in the exercise of the official authority vested in us as data controller.
Vital interests
Exceptionally, we may process your personal data when necessary to protect your vital interests or those of another natural person.
We will process the data provided on any of the Website’s infored contact channels, such as email, mail, or telephone call, in order to fulfil the purposes set out in the section "Data processing purposes.”
The data received by Impulsa shall be treated with utmost discretion and confidentiality. Impulsa has established all technical and organizational means at its disposal to prevent the loss, misuse, alteration, unauthorized access, or copying of data provided.
Depending on the different Website forms, services and content accessed, or the processing operations performed, personal data may be processed for the following purposes:
Contact
If you contact us through the channels provided on the Website, we will process your data to respond to your requests, queries, or contact you. If you contact us by telephone through the contact telephone number indicated on the Website and we are not able to answer your call, you may leave a voice message and our staff will contact you as soon as possible.
Legal basis: Legitimate interest
Contracting
We will process your data to manage our business relationship with you, to provide you with assistance, or to respond to queries or requests related to our services.
Legal basis: Contract execution or implementation of pre-contractual measures
Recruiting
Personal data collected through the join [email protected] mailbox or any other email address of Impulsa will be processed for the purpose of managing unsolicited applications or specific vacancies, checking academic records and work experience, as well as to contact the candidate, call him/her for selection tests, and selecting suitable candidates. If given candidate consent, we will keep the data for an additional period of time to contact and inform him/her of other career options in our company.
Legal basis: Pre-contractual measures or consent (for the prolonged retention of a cv).
Access control
For managing visits to our office, we may request your identification information.
Legal basis: Legitimate interest
Cookies
For more information about the way we process your data using cookies, please refer to our Cookie Policy, located at the footer of the Website.
Other Purposes
Any other data processing purpose not mentioned in this section will be duly communicated before proceeding to process your personal data.
In general, your data will not be sold, rented, or made available to third parties. Exceptionally, data may be disclosed to administrative or judicial authorities when required. Apart from the aforementioned cases, your personal data will not be disclosed to any third party without your prior consent.
Additionally, certain data processors providing support services to Impulsa, such as external service providers belonging to the information systems and technology sector, may have access to your data, but under no circumstance are they allowed to process the data for their own purposes.
Your data will be kept for the time strictly needed to achieve the purpose of processing, without prejudice to its retention for making it available to competent authorities and for dealing with claims.
Data protection regulations in force grant you the following rights:
Right of access
You have the right to know the personal data we hold and process in relation to you.
Right to rectification
You have the right to rectify or amend any personal data that is inaccurate or incomplete.
Right to erasure
You may request that your personal data be deleted from our systems and files.
Right to object
You may object to the processing of your data unless the basis for the processing is legitimate interest.
Right to restriction
You may request a restriction to the processing of your data, in the case of contesting its accuracy or when it is unlawful, thereby objecting to the deletion of your personal data and requesting instead the limitation of its use.
Also, when the data is no longer necessary for processing, but you need it for the formulation, exercise, or defense of claims.
And finally, you may exercise this right when you object to the processing of your data, while awaiting verification as to whether the legitimate interest of the controller outweighs that of the person concerned.
Right to data portability
You have the right to obtain a copy of all the information you have provided us and, where technically feasible, you have the right to request that your personal data be disclosed to another data controller.
You may exercise these rights free of charge, as well as withdraw your consent at any time, by contacting Impulsa (see the contact details in the section "Data controller" of this Privacy Policy). Be aware that Impulsa may require that you enclose a copy of your ID card, or equivalent document, in order to verify your identity when deemed necessary.
For any queries or suggestions regarding the processing of your personal information, you may also contact us at the same address.
Furthermore, you have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD, for its initials in Spanish), the control authority in Spain with regards to data protection, if you consider that your data has not been processed correctly.
If any of our service providers processes personal data in a third country, Impulsa will implement all measures and controls within its power to protect your personal data. The main measures taken by Impulsa with respect to international transfer of personal data, include the signing of standard contractual clauses approved by the European Commission, adherence to international agreements or adequacy decisions, and the request of approved and recognized certifications or codes of conduct.
Last updated: 25 October 2022