Global Privacy Policy

The security of personal data has become one of the top priorities for organisations, and in a global and highly interconnected company like ours, guaranteeing the inviolability of this information has to take top priority. In this regard, we want to be transparent and ensure that this Privacy Policy is at the disposal of all those who interact with us.

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.

This policy applies to Acciona, S.A. and all the companies in the Acciona Group, defined as those in relation to which Acciona, S.A., exercises, directly or indirectly, control over their capital and/or management, and whose composition can be checked at any time at https://www.acciona.com/shareholders-investors/financial-information/annual-accounts/, (referred to collectively as “ACCIONA”). Any references in this Privacy Policy to "ACCIONA", "us", "we" and "our" concern the entity responsible for processing your personal information that, generally speaking, will be that which gathers and processes it.

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.

This Privacy Policy applies to all Users, understood to mean those who visit the website and any other person who suppliers their personal data for use via the different channels (“User” or “Users”). In this context, Channels refers to the different means or services that we place at your disposal so that you can interact with us, whether or not they involve registration, such as webs, applications, platforms, mailboxes, addresses or User information or assistance telephone numbers, social media profiles, forms, events, etc.

Some of our on-line Channels may contain links to other third-party websites and applications not related to ACCIONA. This Privacy Policy does not apply to the same. Please also revise the Privacy Policies of such third parties with a view to familiarising yourself with their practices. They may also contain third-party cookies that are not owned or controlled by ACCIONA. In this case, you can choose your third-party cookies configuration using our Cookies Configuration Tool, situated at the bottom of each of ACCIONA’s websites, where you will be able to manage your preferences and which you can access by clicking on "Cookies".

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.

Who is responsible for personal data processing?

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.

With regard to this Privacy Policy and this website, we inform you that the data controller is:

  • Company name: Acciona, S.A.
  • Tax ID no.: A08001851.
  • Address: Avenida de Europa, número 18, Parque Empresarial de la Moraleja, 28108 Alcobendas (Madrid).
  • Telephone: +34 91 663 28 50
  • Email: accionacorp@acciona.com

The User will be able to contact the Data Protection Department to clear up any queries he/she may have regarding the processing of personal data at the postal address provided above or at the following email protecciondedatos@acciona.com

What data can we receive via our channels?

For the purposes of this Privacy Policy, “personal data” refers to the data which identifies a person or can be used to identify them.

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.

What is the purpose and legitimacy of personal data processing by ACCIONA?

ACCIONA processes the personal data of the Users, gathered via any of our Channels, with the following purposes and legitimate grounds:

  • Manage the relationship established with us
    • In those services we provide via APPs or web platforms, we process the data supplied by Users with the purpose of managing access credentials, providing assistance, responding to enquiries and administering our products and services.
    • We also process the data for the purpose of catering for requests for services and information from our Users received via any of our Channels, as well as for processing any suggestions, claims or complaints.
    • We also process data when a User subscribes to any of our alerts Channels, Newsletters, products and/or services news bulletins or requests the sending of commercial communications.

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.

  • Manage requests and participation in our recruitment processes

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

  • Manage contact details in the context of contractual or commercial relations

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. 

  • Compliance with the legal obligations that affect us.

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. 

  • Fraud management

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.

  • Statistics and satisfaction surveys

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.

  • Security and surveillance of premises

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.  

  • Managing visits and third parties

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.

  • Managing the Whistleblowing Channel

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.

  • Information on third parties

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.

  • Public information

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.

For other specific processing, see the Further information section of this Privacy Policy

For how long does ACCIONA store the User’s personal data?

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.

In particular:

  • Data gathered to process requests or enquiries will be stored for the time necessary to respond to the same.
  • Data gathered based on your consent will be stored unless it is withdrawn.
  • In all other cases, the User will be informed of the storage terms applicable to the specific processing.

To whom can ACCIONA disclose the User’s data?

At ACCIONA, we undertake not to assign or disclose the personal data of our Users except where described in this Privacy Policy or, if applicable, at the time the data is gathered.

  • We may exchange personal information with service providers which are ACCIONA companies or third parties, in some cases hired to provide services on our behalf. In these cases, where necessary, the corresponding processing agreements will be signed in accordance with the regulations on data protection.
  • We can disclose your personal information (1) in the event you allow us to or if required by law or a legal process (such as a court order or summons); (2) to the police authorities or other public officials in order to comply with a legal, legitimate request; (3) when we consider it necessary to avoid physical harm or financial loss; (4) in order to establish, exercise or defend our legal rights; (5) in relation to the investigation of a suspected or proven case of fraud or unlawful activity; or (6) with the consent of the User.
  • We reserve the right to transfer to a third party any information we have on Users in the event of an actual or potential transfer or sale of all or part of our business or assets (including mergers, acquisitions, joint ventures, restructurings, assignments, dissolution or liquidation) or other structural or commercial operations. In that case, such third parties will be required to ensure levels of protection that are comparable to those provided by ACCIONA in relation to the information to be shared.
  • ACCIONA is a Global interconnected company, meaning that we may exchange personal information among Group companies in the context of the centralisation of certain activities. You can consult the composition of ACCIONA at any time in the report on the latest consolidated annual accounts, https://www.acciona.com/es/accionistas-inversores/informacion-financiera/cuentas-anuales/. Nonetheless, this transfer, assignment and processing of Personal Data within ACCIONA is carried out under the data protection legislation in force and by the adoption and application of appropriate safeguards to ensure the protection of privacy and the fundamental rights and freedoms of Users.

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

Social media

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.

Personal data of minors

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 protecciondedatos@acciona.com

Direct marketing

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.

Automated decisions

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. 

Persons attending Events organised by ACCIONA

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.

  • Image: In addition to the processing derived from the security and surveillance of our premises, as a result of User participation in Events, their image and, on occasion, their voice may be recorded and processed by ACCIONA in the form of photographs and/or video recordings. Whenever the Events involve this processing, we will inform the User expressly. This processing may be for internal, external and/or Event promotion purposes, meaning that the material may be used for reproduction, distribution, transformation, public communication, recording and placing at disposal in any format or medium (including, but not limited to, exploitation via analogue or digital media and via the Internet, such as websites or intranets belonging to ACCIONA GROUP entities) without such activities granting a right to remuneration, consideration or any other financial benefit for the User.

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.

What are the User’s rights when we process his/her data?

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 the form available at the link.

ACCESS FORM:

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.

Further information

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.

Validity

Any change to the Privacy Policy and in the information administration practices will be duly reflected and ACCIONA will add to, modify or replace this Policy when it considers it necessary.

Last update: October 05, 2020.