Privacy Policy

1. Data Controller

ATH21 S.L.P.U., a company with registered office at Plaza Vannes, 1, entlo B, 46007, Valencia, with NIF B98216617, (hereinafter, “ATH21” or the “Company“) is responsible for the processing of your personal data. This privacy policy provides information regarding the processing of personal data of our customers, potential customers and suppliers, job candidates, users who contact us through any form on the web or social network users who interact with us, in accordance with the provisions of the General Data Protection Regulation (“GDPR”).

You can contact us by writing an email to privacy@ath21.com to resolve any questions you may have regarding this policy. If you wish, you can request a list of recipients of your data at the same email address.

2. Processing of data of customer representatives or individual entrepreneurs

If you are a client of ATH21, because you have accepted a proposal of professional fees for our services, we will treat your data as indicated below:

• Purpose of processing: We process your data to maintain, fulfill, develop, control and execute the contractual relationship we have with the company you represent, ATH21 client, or with you, if you are an individual entrepreneur. In addition, we may send you commercial communications about our services, to keep you informed about news taking into account your interests and/or information related to ATH21 services.

• Legal basis for processing: We will process your data to fulfill our contractual relationship. Regarding the sending of commercial communications, ATH21 has a legitimate interest in keeping the entity you represent informed about our services and legal developments.
• Recipients of your data: Your personal data will be accessed by some of our technology and management service providers who, in order to perform the service they provide to us, have to access our customers’ data (e.g., email server, cloud hosting systems or management). These service providers will process your data according to our instructions and with the signature of the corresponding confidentiality agreements. Also, on certain occasions, it may be necessary to communicate your data to judges, courts, solicitors, experts, notaries or registrars, in order to complete the services we provide to the ATH21 client you represent. If you are self-employed, we may transfer your identification and bank account information to our bank in order to complete the corresponding payments.
• International data transfers: To provide our services, we use the services of technology providers who need to access your personal data from countries located outside the European Economic Area. The services of these providers, therefore, imply the existence of an international transfer of your personal data, which could imply a lower degree of protection than that provided for in the European regulations. However, all providers of this type have signed the corresponding standard contractual clauses approved by the European Commission, an agreement signed between the two entities by which the provider guarantees that it applies European data protection standards. Therefore, the use of these providers does not result in a lesser degree of protection of your personal data than would be the case with the use of providers located in the European Union. You can request an updated list of these recipients by sending an email to privacy@ath21.com.
• Period of conservation of your data: Your data will be kept during the execution and maintenance of the contractual relationship between the entity you represent and ATH21 and, subsequently, blocked during the legal periods of conservation. Regarding the sending of commercial communications, remember that you can request at any time that we stop sending these communications, through the link included for this purpose in all our advertising communications.

3. Processing of potential customer data for advertising purposes

If you are not yet a client of ATH21, but you want to receive our communications informing you of news related to the services we offer, we will treat your data as indicated below:

• Purpose of processing: We process your data to keep you informed about news related to ATH21 services and legal developments taking into account your interests and / or navigation.
• Legal basis for processing: Your express consent, which you will give by subscribing to our commercial communications or by ticking the specific box indicating this in other forms.
• Recipients of your data: Only some of our technology service providers who, in order to perform the service they provide to us, have to access our customers’ data, will have access to your personal data. These service providers will process your data according to our instructions and always under our control.
• International data transfers: To provide our services, we use the services of technology providers who need to access your personal data from countries located outside the European Economic Area. The services of these providers, therefore, imply the existence of an international transfer of your personal data, which could imply a lower degree of protection than that provided for in the European regulations. However, all providers of this type have signed the corresponding standard contractual clauses approved by the European Commission, an agreement signed between the two entities by which the provider guarantees that it applies European data protection standards. Therefore, the use of these providers does not result in a lesser degree of protection of your personal data than would be the case with the use of providers located in the European Union. You can request an updated list of these recipients by sending an email to privacy@ath21.com.

Period of conservation of your data: Your data will be kept for as long as you wish it to be so, since you can request at any time that we stop sending you these communications, through the link included for this purpose in all our advertising communications.

4. Data processing by contact through the form, email or chat.

In case you have provided your data through the ATH21 web forms to ask a question or contact us, we will treat your data as indicated below:

• Purpose of processing: We process your data to assist you and serve you whether you are a customer or potential customer of ATH21.
• Legal basis for processing: Your express consent, granted by voluntarily sending your query, request or other communication through our contact form, email or other means that we make available to you for this purpose.
• Recipients of your data: Only some of our technology service providers who, in order to perform the service they provide to us, have to access our customers’ data, will have access to your personal data. These service providers will process your data according to our instructions and always under our control.
• International data transfers: To provide our services, we use the services of technology providers who need to access your personal data from countries located outside the European Economic Area. The services of these providers, therefore, imply the existence of an international transfer of your personal data, which could imply a lower degree of protection than that provided for in the European regulations. However, all providers of this type have signed the corresponding standard contractual clauses approved by the European Commission, an agreement signed between the two entities by which the provider guarantees that it applies European data protection standards. Therefore, the use of these providers does not result in a lesser degree of protection of your personal data than would be the case with the use of providers located in the European Union. You can request an updated list of these recipients by sending an email to privacy@ath21.com.
• Period of conservation of your data: Your data will be kept for this purpose until we solve your query and, thereafter, during the legal periods of conservation.

5. Data processing of candidates who leave their resume in the “Work with us” form or via e-mail.

If you are a candidate for employment at ATH21 and you have sent us your resume through our web tool, or via email, we will treat your data as indicated below:

• Purpose of processing: We process your data to study your current or future application for a job at ATH21.
• Legal basis for processing: Your express consent, granted by voluntarily sending your resume and personal data through our form, email or other means that we make available to you for this purpose.
• Recipients of your data: Only some of our technology service providers who, in order to perform the service they provide to us, have to access our customers’ data, will have access to your personal data. These service providers will process your data according to our instructions and always under our control.
• International data transfers: To provide our services, we use the services of technology providers who need to access your personal data from countries located outside the European Economic Area. The services of these providers, therefore, imply the existence of an international transfer of your personal data, which could imply a lower degree of protection than that provided for in the European regulations. However, all providers of this type have signed the corresponding standard contractual clauses approved by the European Commission, an agreement signed between the two entities by which the provider guarantees that it applies European data protection standards. Therefore, the use of these providers does not result in a lesser degree of protection of your personal data than would be the case with the use of providers located in the European Union. You can request an updated list of these recipients by sending an email to privacy@ath21.com Period of conservation of your data: Your data will be kept for one year from the receipt of your resume and then blocked during the legal periods of conservation.

6. Processing of data of users of social networks that interact with ATH21 profiles in these social networks.

If you are a user of a social network and interact with any profile or page of ATH21, we will treat your data as indicated below:

• Purpose of processing: We process your data to interact with you in a normal way according to the policies of the social network, and to manage our virtual communities according to the policies of each social network and our interests (both yours and ours).
• Legal basis of treatment: When you become a follower of any of our pages on social networks, the processing of data will be governed by the terms of use, privacy policies and access regulations belonging to the corresponding social network and previously accepted by the user.
• Recipients of your data: No third party will have access, through ATH21, to your user data of the social network.
• Retention period of your data: We will retain your data only for as long as necessary to resolve your inquiry, or for the duration of our interaction. Please note that while we will not specifically store this data, your data may remain on the social network depending on the operating policy of each specific social network.

Please note that we have no influence over the information that the social network collects or how it processes it, so we recommend that you keep yourself informed of the purpose and scope of the collection of information that is done through such social networks.

7. Processing of supplier representative data

If you are a representative or contact at an ATH21 supplier with whom our employees maintain contact, we will treat your data as indicated below:

• Purpose of processing: We process your data to maintain, fulfill, develop, control and execute the commercial relationship we have with the supplier you work for or with you in case you are self-employed.
• Legal basis for processing: We will process your data to fulfill our business relationship.
• Recipients of your data: Only some of our technology and management service providers who, in order to perform the service they provide to us, have to access the data of representatives of our suppliers will have access to your personal data. These service providers will process your data according to our instructions and always under our control.
• International data transfers: To provide our services, we use the services of technology providers who need to access your personal data from countries located outside the European Economic Area. The services of these providers, therefore, imply the existence of an international transfer of your personal data, which could imply a lower degree of protection than that provided for in the European regulations. However, all providers of this type have signed the corresponding standard contractual clauses approved by the European Commission, an agreement signed between the two entities by which the provider guarantees that it applies European data protection standards. Therefore, the use of these providers does not result in a lesser degree of protection of your personal data than would be the case with the use of providers located in the European Union. You can request an updated list of these recipients by sending an email to privacy@ath21.com.
• Period of conservation of your data: Your data will be kept during the execution and maintenance of the contractual relationship with the supplier you work for, or with you in case you are self-employed, and subsequently blocked during the legal conservation periods.

You may exercise the following rights before ATH21:

• Right of access to your personal data to know which are being processed and the processing operations carried out with them;
• Right to rectify any inaccurate personal data;
• Right of deletion of your personal data, when possible;
• The right to request the limitation of the processing of your personal data when the accuracy, lawfulness or necessity of the data processing is in doubt, in which case, we may retain the data for the exercise or defense of claims.
• Right to object to the processing of your personal data: (i) provided through the forms, email or chat ATH21; (ii) provided through a social network; (iii) relating to your curriculum; (iv) if you are a representative of a supplier and/or provider; (v) if you are a representative of a client and/or customer of ATH21. Likewise, you may withdraw your consent to receive commercial communications at any time, through the link included for this purpose in each commercial communication.
• The right to portability of personal data that you have provided to us and that concern you, when you are a potential customer and have given your consent to receive commercial communications from us. Portability consists of receiving the personal data you have provided to ATH21 in a structured, commonly used and machine-readable format, and to transmit the data to another data controller when the processing is carried out by automated means.

You may exercise your rights at any time free of charge by sending an email to the following address: privacy@ath21.com. You must specify which right you wish to exercise, as well as your identification data. If, in order to verify your identity, we need additional information from you, we will let you know.

If you believe that ATH21 has committed a breach of personal data protection legislation, please do not hesitate to contact us at the e-mail address privacy@ath21.com, telling us what you think, so that we can solve the problem as soon as possible. In any case, you can also bring it to the attention of the Spanish Data Protection Agency (www.aepd.es) and claim before this body the protection of your rights.

8. Email Policy

All our e-mails are professional and confidential. Its use by recipients is subject to the following rules:

• Confidentiality
  The information contained in this email is strictly confidential. The use or disclosure without prior written authorization of any part of the mail may violate the rights of its legitimate owner or even constitute a crime.
• Professional use
  All our e-mails are of a professional nature and are governed by the ethical rules applicable to lawyers and legal professionals. This provision particularly affects communications exchanged with other lawyers and colleagues.
• What to do in case of error?
  If, for any reason, you are not the addressee of this e-mail, please inform the sender of the e-mail and/or contacto@ath21.com immediately. We also ask you to delete it permanently from your mailbox and not to forward it to third parties or make any other use of it, in order to avoid civil and criminal liabilities.

International data transfers:

In order to provide our services, we may use third party technology providers who may access your personal data from countries outside the European Economic Area. The services of these providers, therefore, imply the existence of an international transfer of your personal data, which could imply a lower degree of protection than that provided for in the European regulations. However, in the event of such an eventuality, the corresponding measures would be applied, as well as the formalization of the standard contractual clauses approved by the European Commission. You can request an updated list of these recipients by sending an email to privacy@ath21.com.