This Policy is of a global nature because, although each time we gather your data, we will provide you with specific information on the processing, we want to place this document at your disposal in which you can find and consult the general, relevant information on our practices in relation to Personal Data processing, as well as our relations with those third parties who may access the same or gather it on our behalf.
One of ACCIONA’s principles is respect for the legislation in each of the countries in which it operates, adapting its information systems to the specific regulations on the processing of the data of any person who, for whatever reason, has dealings with us. ACCIONA undertakes to process the personal data in accordance with the regulations on personal data protection and, specifically, wherever applicable, with the terms 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, in line with the local legislation applicable in each case, meaning that in some jurisdictions this Policy may be supplemented by the corresponding local legislation.
ACCIONA adopts the technical and organisational measures necessary to guarantee the security of personal data and avoid any alteration, loss, unauthorised processing or access, according to the state of the art, the nature of the data and the risks to which it is exposed. You can also verify the presence of the SSL certificate by checking the Page properties in your browser. A connection will be secure when the address bar of the browser displays "https://" instead of "http://" and the padlock symbol appears. You can consult further characteristics of the SSL certificate in the Legal Notice section.
Whenever personal data is gathered and processed, we will inform the User of the ACCIONA company responsible for processing and will supply them with the corresponding identification details.
ACCIONA informs its Users that personal data, obtained via the Channels it owns or holds, will only be gathered for processing when appropriate, pertinent and not excessive in relation to the specified, explicit and legitimate ambit and purposes for which it was obtained.
When, via our Channels, personal data is gathered for specific purposes, the User will be informed clearly and unequivocally in advance of i) the controller and its contact details, iii) the purposes of the specific processing and the legitimacy for it, iv) the recipients or categories of recipient, if applicable, as well as the existence of international transfers, if any, v) the storage criteria or terms, and vi) their rights as an interested party.
The User is also the only person responsible for the information supplied and for the veracity and lawfulness of the same.
ACCIONA processes the personal data of the Users, gathered via any of our Channels, with the following purposes and legitimate grounds:
In these cases, the legal basis for the processing is the consent given by the User, as well as the performance of the agreement and/or the legal relations established with ACCIONA.
Through our Employment Channel, any interested party can apply for job vacancies, grants and/or specific programmes. The data and documentation received are processed in this scenario in order to assess candidates and, where you provide consent, consider you for other possible vacancies at ACCIONA, which could imply the data being shared with the Group company responsible for the vacancy in question.
The legal basis for processing is the application of pre-contract measures and the consent provided when opting for potential vacancies.
Full information on this processing is at your disposal via the following link: https://mediacdn.acciona.com/media/izrfcyvc/privacy-policy-workday.pdf
We process contact details of potential clients; legal representatives of legal persons and bodies, whether public or private; analysts and investors; or other parties intervening, who supply their data, with a view to sending them information of interest, managing the commercial relationship between us, managing invitations or notices regarding events organised or sponsored by ACCIONA or in which it participates.
The legitimacy is maintaining the contractual and/or commercial relationship between us, or where there is none, the consent stated by the User in providing contract details.
Whether these legal obligations are of a commercial, tax, accounting or administrative nature; the legal basis entitling us to process data is compliance with legal obligations.
In some of the services we provide, it is necessary to verify identity in order to offer protection, detect and prevent fraud or other unlawful activities, unauthorised transactions, claims and other kinds of responsibilities, as well as to manage the quality and risks associated with the business; and investigating where necessary, any unlawful activities and potential breaches of our policies and/or the conditions of our services.
The legal basis is compliance with the applicable legal obligations in each case. Among others and by way of example, Act 10/2010 of 28 April on the Prevention of Money Laundering and Terrorist Financing.
We can process User data for statistical purposes, in order to analyse conduct and trends in order to improve our services. The legitimacy for this processing is the legitimate interest of ACCIONA in assessing our products and services.
For this purpose, data obtained in satisfaction surveys regarding our services may be processed, as well as the cookies gathered from browsing websites. The legitimacy in this case is the consent given by the User.
Our premises have cameras and video-surveillance systems in order to ensure the security of assets and persons.
The legitimacy for processing is the legitimate interest of ACCIONA in guaranteeing security in its premises.
With a view to monitoring access to the premises by visitors, collaborators or other third parties, it is possible that identification details will be gathered at some premises.
The legitimacy in this case is the consent given as well as ACCIONA’s legitimate interest in guaranteeing the security of assets and persons in its premises.
In the framework of the COVID-19 pandemic, complementary access control measures have been established. You can see all the information about Personal Data Protection, clicking here.
ACCIONA has a reporting channel, called the Whistleblowing Channel, that can be used by employees, suppliers or third parties to confidentially report any breaches of which they are aware.
The legal basis for the processing of data in this case, is compliance with legal obligations in the investigation of potential offences.
When the User provides data in relation to third persons, whether voluntarily or because we request it in order to comply with a legal obligation, the User consents to the processing and declares that the data is accurate. Likewise, the User declares that it has specifically informed third persons of the content of this policy and/or any other applied, and of the corresponding rights with regarding to Personal Data Protection. The above notwithstanding, ACCIONA will use its best endeavours to act properly in relation to processing of such third parties.
ACCIONA may process that information to which it has access as information that is lawfully available to the public and, in particular, any public information available in official registries. In any event, this processing will only take place if there is a legitimate basis as set out in the applicable legislation and, whenever it is possible or a contractual relationship exists, will be informed.
In general terms, the data will be stored (i) for the time necessary for the purpose for which it was gathered, (ii) for the applicable expiry terms, in case liabilities derived from the processing arise.
Likewise, ACCIONA informs that some of its service providers, third parties or Group companies may be located outside of the European Economic Area in territories that do not offer a level of data protection that is comparable to that of the European Union. In such cases, we transfer User data with appropriate safeguards and always ensuring the security of the same, such as the formalisation of Standard Contractual Clauses of the kind approved by the Commission, the content of which can be consulted via the following link: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
At ACCIONA we use social media such as LinkedIn, Twitter, Facebook, Google+, Instagram or YouTube, to share our content. We act as data controller for the data we publish online, processing it always in accordance with the conditions established for each of the social media outlets.
Interaction with Users due to the use of such profiles or tools may imply an international data transfer, of an analytical and technical nature, in relation to the Website and the social media profiles, with the data supplied by Users via such profiles being processed on the servers of the social media companies.
ACCIONA does not deliberately gather personal data of minors, without the authorisation of their parents, representatives or legal guardians. None of the Channels offered to Users by ACCIONA are designed for or directed at minors.
If parents, representatives or legal guardians consider that their underage children have supplied personal information without their consent, we ask that they contact us at the following email email@example.com.
Generally speaking, ACCIONA does not use the personal data of Users for direct marketing purposes, unless consent is obtained in advance.
Users can, at any time, opt out of any direct marketing campaigns and oppose the future transfer of their personal data for such purposes, sending us an email to the address of the Data Controller using the corresponding "unsubscribe" option, included in the emails.
At ACCIONA we do not carry out automated decision-making, including the preparation of profiles, except where expressly notified and the express consent of the User is requested.
At any acts, training sessions, meetings, initiatives, etc. (“Events”), organised or promoted by ACCIONA, in its premises or elsewhere, we may ask the User to supply personal data in order to duly manage such Events and attendance at the same. This data may, among other things, be related to managing access, accreditation, transport and travel, accommodation, catering, delivery of related documentation, etc. This processing will be based on consent and, in certain cases, on fulfilment of a contractual relationship or legal obligation.
This data may have to be disclosed to some of the service providers or collaborator or sponsor entities, participating or intervening in the Event. As a general rule, we will only store this information for the time strictly necessary to hold the Event and, if appliable, to comply with any applicable expiry deadlines.
This processing is based on consent, whether individually and expressly granted, where possible, by the User, or due to attendance at Events in relation to which the User was informed of image processing in advance. The authorisation of the User will be worldwide in scope, transferrable (within ACCIONA and externally) and for the duration of the intellectual property rights. The User may revoke consent at any time, via the appropriate Channels.
The intellectual and industrial property rights of materials generated in the context of Events and activities correspond exclusively to ACCIONA.
The User can exercise his/her rights of access, correction, erasure, data portability, and/or the limitation of or opposition to processing, before the corresponding data controller, or by writing to the Personal Data Protection Department at Avenida de Europa, 18, 28108 Alcobendas (Madrid), or by sending an email to: firstname.lastname@example.org. If we consider it necessary in order to be able to identify you, we may ask you for a copy of an identity document.
Likewise, you may withdraw consent at any time by writing to the address indicated above, as well as by presenting a complaint to the corresponding Supervisory Authority on data protection (https://www.agpd.es/portalwebAGPD/index-ides-idphp.ph) and, in particular, to the Spanish Data Protection Agency (www.aepd.es).
Remark: During exceptional periods such as States of Alarm or Emergency, implying periods of lockdown or other external disturbances such as natural disasters, extreme climate events or wars, the rights not exercised via email and exercised by standard post will involve a longer than usual time of reply, with the times of reply being restored when the recommended lockdown period has ended.
Below is a series of links where you will be able to obtain further information on specific data processing for candidates, supplies, investors and shareholders, the Whistleblowing Channel, as well as on clients and potential clients. You can also obtain information on the website in the legal notice.
Last update: September 14 2020.