PRIVACY POLICY

1. INTRODUCTION

At GEMINIS LATHES S.A., we are committed to privacy protection and the proper use of the personal data that we process and that you provide to us, both online on this Website and, if applicable, any of its subdomains, microsites, and offline.

Please read this policy carefully and ensure you understand it and agree with it before providing your personal data. If you do not agree with it, please refrain from using this Website or its services and do not provide us with your data.

The act of accessing this site, using any of its services or providing your data, either online or offline, will be understood as an affirmative act through which you give your consent (when this is necessary) to process your data for the purposes indicated below.

2. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?

GEMINIS LATHES S.A.
Postal address: C/Lerun,1 – 20870 Elgoibar – Gipuzkoa - Spain
Email: sales@geminislathes.com
Telephone: (+34) 943 748 060

3. HOW HAVE WE OBTAINED YOUR DATA?

3.1. Obtained from the interested party themselves

If you are a current or potential customer or User of our Website, you have provided it yourself, either offline or online by requesting our products or services, or by contacting us to request information.

When you provide your data, you are guaranteeing that you are entitled to provide this information and that it is true, up to date and does not breach any contractual restriction or third-party rights. You are responsible for keeping your data and your profile correct and up to date. GEMINIS LATHES S.A. accepts no responsibility if you do not do so. You agree not to impersonate other Users by using their registration data for the different Website services and/or content.

3.2. Obtained automatically due to visiting our Website

When you visit our Website, we compile information through cookies and other tracking and web analytics technologies. This means that data is sent from your browser to our servers to optimise our services and improve your User experience. This data may be gathered and stored automatically by us or by third parties on our behalf. You can consult our cookies policy.

3.3. Obtained from a person other than the interested party

It is possible that you have not directly provided us with your data, but that it has been provided by a third party with whom we work, to whom you have previously provided this data. For example:

• Our commercial or distributor network, prior provision of your data to one of our sales representatives.

Regarding the other people’s data, their privacy must be respected and special care taken when communicating or posting their personal data. Only the holder can authorise the processing of personal data. The publication of third-party data without their consent may infringe, in addition to the data protection regulations, those related to the right to honour, privacy or the image of these third parties.

It is the responsibility of the party who provides third-party data to: a) have their prior, express consent to use it, and b) inform them of the processing we are going to carry out with their data. Through the acceptance of this privacy policy, whoever provides third-party data expressly guarantees that they have authorisation to provide it, exempting us from any responsibility in the event of any complaint by the interested party.

4. WHAT CATEGORIES OF DATA DO WE PROCESS?

The data categories we process may be:

• Obtained from the interested party themselves: identification data (full name, tax code), contact details (telephone, postal address, email address, billing or delivery address), commercial and economic data (information on the products requested, customer history, and data necessary for payment: bank, credit card, etc.)
• Obtained automatically due to visiting our Website: User IP address, the date and the time of the visit, the URL of the site from which the User has arrived, the pages of our Website visited, information on the browser used (browser type and version, operating system, etc.). Also data from online profiles (information on preferences and interests, browsing or purchasing habits, the sales actions performed or the information you have requested), to be able to send you personalised information or exclusive campaigns, etc.
• Provided by a third party: identification data
• Regarding data with special protection: We do not process special categories of data

5. WHAT DO WE PROCESS YOUR DATA FOR?

The data you have provided, as well as the data generated during the course of the relationship we maintain with you, can be processed for different purposes:

General purposes:

• If you are a current or potential customer: to maintain contact and communication with you, and manage the contractual and/or commercial relationship.
• If you have used our Website, or have sent or received an email: to manage the requests you make online, and to contact you.
• In the event you access our premises as a visitor: for access management and visitor control.

Specific purposes:

• In the event you have provided your CV: to contact you and manage the selection process we are conducting. In this case, you must accept the privacy policy, marking the field for this purpose. If you do not give your consent, we cannot take your CV into account.
• To protect the vital interests: of the interested party or another third party.

Purposes with special duty of information:

• To send you, by electronic communication, information about our activities, products and/or services similar to those requested, including advertising and/or commercial communications to the effects of art.21 LSSICE 34/2002. If we already have a prior contractual relationship, these communications will be sent based on our legitimate interest. If we do not have a prior contractual relationship, we will only send you this type of communications if you have authorised them by marking the option that is expressly included for this purpose in the corresponding forms. The electronic communications we will send you will include, in the communication itself, the option to stop receiving them. If you opt for this, we will stop sending any further communications of this type from then on.
• To transfer your data to other companies or entities, directly related to GEMINIS LATHES S.A., to be able to provide the service or product that you have requested, and the administrative and accounting management that this provision requires. Specifically, we can communicate your data to the recipients set out in the specific section further down in this policy.

6. WHAT IS THE LAWFUL BASIS FOR PROCESSING YOUR DATA?

• Fulfillment of the existing legal contractual or commercial relationship if you are already a customer, supplier, or participant in our activities. If you are a potential customer or supplier, it is the precontractual relationship that links us.
  • The provision of the data requested is compulsory as it is required to enter into and/or maintain the contractual or precontractual relationship and comply with the legal obligations deriving therefrom; if you do not provide it, we will not be able to provide the service resulting from this relationship.
• Consent: It may also be the case that you have granted us your consent for a specific purpose: For example: for the sending of commercial communications, if you have entered our Website, if you have visited our premises, if you have sent us your CV, if you have given your consent for taking photographs, etc.
  • This consent is granted to us unequivocally when you provide your data on- or offline, as this provision is deemed a clear affirmative act declaring this consent. The provision of the data requested is compulsory as it is essential to attend to your request; if you do not provide it, we cannot fulfil it. You can withdraw this consent at any time by sending us an email stating this to sales@geminislathes.com. This withdrawal will not affect the processing of your data for the other purposes described, but this may mean we are unable to respond to your request.
• Fulfillment of a standard or legal obligations: such as those established in regulations on finance, tax, social security, occupational risk prevention, consumers and users, penal code (art.31 bis: establishment of reporting channels), etc.
• Our legitimate interest as an organisation also constitutes a legal basis for using your data, provided that this legitimate interest is foreseeable by you and that you can reasonably expect that we will use it for this interest when we collect it depending on the relationship or service that links us. E.g. to:
  • Inform you of our activities, products and/or services, even by electronic communication, if we already have a prior contractual relationship with you. Otherwise, we will only send you this type of communications if you authorise it by marking the option that is expressly included for this purpose in the corresponding forms.
  • In any event, we deem the indicated processing of your data proportionate and that it has minimal impact on your privacy. However, your interests, rights and freedoms will always prevail over our legitimate interest, so if you would prefer we did not process your data for these purposes, please send us an email stating this to sales@geminislathes.com, and we will do so.
  • Respond to the requests or orders you make, e.g. via the forms on our Website.

7. HOW LONG WILL WE KEEP YOUR PERSONAL DATA?

7.1. General storage period

The personal data that you provide will be stored while the contractual, precontractual or commercial relationship is maintained and, once these come to an end, while the interested party does not request its deletion. Even if their deletion is requested, we will be able to hold it for the time needed, limiting its processing, only to:

• Fulfil the legal/contractual obligations to which we are subject,
• and/or for the legally established period for the expiry of any responsibilities on our part,
• and/or the exercise or defence of complaints stemming from the relationship maintained with the interested party.

In line with the above criteria, personal data either in electronic records or on paper, may be deleted, at the discretion of the organisation, depending on logistics needs and/or storage space that make it advisable to eliminate information or documentation.

7.2. Specific storage period

• If you have presented your candidacy for employment, by sending us your CV: we will keep it until you request its deletion / for its period of validity, to be able to contact you for the selection process.

8. TO WHOM CAN WE COMMUNICATE YOUR DATA?

We inform you that the data you provide may be communicated to third-party entities for purposes directly related to legitimate functions of assignor and assignee, such as:

General transfers

1. To banking entities: for the management of collection and payments.
2. To the occupational health centre and independent prevention service: in compliance with the obligations of occupational health monitoring and occupational risk prevention.
3. Entities or organisations to which there is a legal obligation to communicate data: for example, Inland Revenue.
4. To notary’s offices, courts or tribunals, registries, public prosecutors, loss adjusters, etc.
5. To insurance companies: for the management and insurance of commercial risks / in case of credit insurance and surety for insurance against collection of transactions or civil liability insurance / to insure against defective products in the event of possible customer complaints.
6. To any of the companies that make up the business Group for internal administrative purposes, include the processing of personal data of customers, suppliers and staff.

9. INTERNATIONAL DATA TRANSFERS

At GEMINIS LATHES S.A., we ensure your personal data is always processed and located in the European Economic Area. Nevertheless, in certain circumstances, we may make international data transfers, for example, in the event it is necessary to enter into or execute a contract, in the interest of the interested party, between GEMINIS LATHES S.A. and another natural or legal person; or in the event it is necessary to execute a contract between the interested party and GEMINIS LATHES S.A. for example when using service providers located outside of the European Union that may have access to personal data, for the purpose of providing auxiliary services for our activity (accommodation, housing, SaaS, remote backups, IT maintenance or support services, email managers, email senders and email marketing, file transfers, etc.) or for the execution of precontractual measures adopted at the request of the interested party.

These entities may be different and vary over time, but we will try to select entities that either belong to countries with a level of protection equivalent to Europe on data protection, or that have appropriate guarantees that this level is met. Otherwise they will be carried out based on one of the exceptions stipulated for this purpose in the GDPR.

10. WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE YOUR DATA?

You may, when relevant, exercise your rights to access, rectify, delete, limit and oppose its processing, as well as other rights, at the postal or email addresses indicated at the top of this privacy policy. In both cases send a signed, written request, attaching a copy of your national identity document, passport or other valid document that identifies you. In the event your data changes, you must report this to the same address; this entity accepts no responsibility if you fail to do so.

• Right to access: You can ask us what personal data we are processing and request a copy thereof.
• Right to rectify: You can request the rectification of incorrect personal data or to complete it if it is incomplete, by means of an additional declaration.
• Right to deletion (the right to be forgotten): You can request we delete your personal data when: it is not necessary for the purposes for which it was collected, you withdraw your consent, it has been processed unlawfully or due to compliance with a legal obligation.
• Right to the limitation of processing: You may request the limitation of processing of your data, in which case we will only store it for the exercise or defence of complaints.
• Right to oppose: You can oppose the processing of your data if this processing is based on the legitimate interest of the person responsible for the file or for advertising purposes.
• Right to oppose automated decisions: You can oppose being subject to decisions based solely on automated treatment of your personal data, including the preparation of profiles that cause legal consequences for you or significantly affect you. E.g. to analyse or predict aspects related to performance at work, economic situation, health, preferences or personal interests, etc. In this case we can draw up profiles on your preferences, if you do not oppose this.

Once we receive any of the above requests, we will respond within the legally established timelines. You may make a complaint before the Spanish Data Protection Agency. If you would like further information about the rights you can exercise and to request the forms for exercising your rights, you can to visit the Website of the Spanish Data Protection Agency, www.aepd.es.