Privacy Policy

Data protection information to our customers

We are committed to protect your personal data and comply with applicable data protection law, in particular the EU General Data Protection Directive («GDPR») and, and we only process your personal data on the basis of a statutory provision or if the data subject has declared consent.

In this data protection information, we explain which information (including personal data) are processed by us in connection with the business relationship between you and us.

1. Who is responsible for the processing of personal data?

The controller responsible for the processing of personal data is URSA INSULATION, SA, Paseo de Recoletos, 3, 28004 Madrid. Any reference to «we» or «us» in this data protection information is a reference to the aforementioned entity.

Our data protection coordinator may be contacted via the aforementioned means or via privacy.ursa@etexgroup.com.

1. Which data do we process?

The performance of our business relationships requires the processing of data related to our customers. If this data concern a natural person (e.g. if you are a single trader and enter into a business relationship with us), it is considered as personal data. Regardless of the legal form of our contract partners, we process data concerning the contact persons acting for a customer.

Please make this data protection information available to the persons within your organization that are involved in the business relationship with us («contact persons«)

1. Basic data:We process certain general data concerning our customers and the contact persons as well as the business relationship with us, collectively «basic data». Basic data include a) any information provided to us in the course of establishing a business relationship or requested by us from our customers or a contact person (e.g., name, address and other contact details; and b) any information collected and processed by us in connection with the establishment of the business relationship (e.g., the details of the agreements entered into)
2. Performance data:We process personal data collected in the course of the business relationship other than by merely updating basic data and that we refer to as «performance data». Performance data include: a)Information on the performance of contractual obligations by our customers on the basis of the agreements entered into; b) Information on the performance of contractual obligations by us on the basis of the agreements entered into; c) Information provided by a customer or a contact person in the course of our business relationship, be it actively or upon our request; and d) personal data that are provided to us in the course of our business relationship by our customer, a contact person or by third parties;
3. To the extent permitted by law, we can add personal data provided by third parties to the aforementioned basic and performance data. Such data may include information regarding the commercial standing / rating of our customers if necessary for the assessment of financial risks (e.g. late payments).a) Information on the performance of contractual obligations by our customers on the basis of the agreements entered into.

III. For which purposes and on which legal basis do we process your personal data?

1. We process basic, performance and usage data for the performance of the contractual relationships with our customers or for pre-contractual measures on the basis of Article 6 para 1 b) GDPR. Regardless of the legal form of our customers, we process basic and performance data concerning one or more contact persons for the purpose of our justified interest in the performance of the business relationship on the basis of Article 6 para 1 f) GDPR.
2. We may process basic, performance and usage data also for compliance with legal obligations to which we are subject; this processing is based on Article 6 para 1 c) GDPR. Legal obligations may in particular include the mandatory disclosure of personal data to (tax) authorities. To extent necessary, we process personal data (in addition to the processing for the purposes of the business relationship or to comply with legal obligations) for the purposes of our justified interests or the justified interests of a third party on the basis of Article 6 para 1 f) GDPR.
   Justified interest may include:
   • group-wide processes for internal administration of customer data
   • the establishment of or defence against legal claims
   • the prevention and investigation of criminal offences
   • maintenance of security for our information technology systems
   • the maintenance of security of our premises and infrastructure
   • management and further development of our business operations including risk management

If we provide to a natural person the option to declare a consent in the processing of personal data, we process the personal data covered by the consent for the purposes specified in such consent on the basis of Article 6 para 1 a) GDPR.

3. Please note that the declaration of consent is voluntarily, that failure to declare consent or the withdrawal of a consent may, nevertheless, have consequences, and we will inform about such consequences before you are given the option to declare your consent consent may be withdrawn at any time with effect for the future, e.g. by providing notice to us via mail, fax, email using the contact information specified on the first page of this data protection notice.
4. Is there an obligation to provide personal data?

The provision of the basic and performance data specified in section II above is necessary for entering into and maintaining a business relationship with us, unless specified otherwise before or at collection of the data. Without the provision of these data, were are not able to enter into and maintain a business relationship.

If we collect additional data, we will indicate if the provision of such information is based on a legal or contractual obligation or necessary for the performance of an agreement. We usually indicate which information may be provided voluntarily and is neither based on a legal or contractual obligation nor necessary for the purposes of an agreement.

1. Who has access to personal data?

Personal data are generally processed within our company. Depending on the categories of personal data, only dedicated departments / organizational units are granted access to your personal data. Such units include in particular the Sale department and – if data are processed via our IT infrastructure – also our IT department. Based on a role / rights management concept, access to personal data is limited to the functions and the extent necessary for the respective purpose of the processing.

If and to the extent permitted by law, we may transfer your personal data to recipients outside of our company. Such external recipients may include affiliated companies within Etex group.

Service providers that – on the basis of separate agreements with us – provide certain services possibly including the processing of personal data, as well as approved subcontractors of our service providers; private or public bodies, to the extent we are obliged to transfer your personal data on the basis of a legal obligation to which we are subject.

1. Do we use automated decision-making?

In the course of the business relationship we generally do not use automated decision-making (including profiling) within the meaning of Article 22 GDPR. If we apply such processes in the future, we will inform data subjects separately in accordance with the applicable statutory provisions.

VII. Are data transferred to countries outside the EU / the EEA?

Personal Information that we collect may be transferred to, and stored at, any of Etex’s affiliates and service providers in countries outside the EEA which do not necessarily offer an adequate level of protection of your Personal Data.

We comply with applicable legal requirements for the above transfer of your Personal Information, including the implementation of appropriate safeguards to ensure its protection. This implies reliance on specific derogations and safeguards set out in the GDPR, including the relevant standard contractual clauses.

VIII. How long are your data stored?

We generally store personal data as long as we have a justified interest in the retention of such data and there the interest of the data subject in refraining from the further processing do not prevail.

Even without a justified interest, we may continue to store the data if there is a legal obligation (e.g. to comply with statutory retention obligations). We delete personal data even without an action by the data subject as soon as further retention is no longer necessary for the purposes for which the data were collected or otherwise processed or if further retention is not permitted by law otherwise.

In general, basic data and the additional data collected in the course of the business relationship at least until the end of the respective business relationship. The data are deleted in any case if the purposes for the collection or processing were achieved. This point in time may be after the end of the business relationship with us. If personal data need to be stored to comply with a legal obligation, such data is retained until the end of the respective retention period. If personal data are only processed to comply with a statutory retention obligation, the access to such data is usually restricted so that the data are only accessible if needed for the purpose of the retention obligation.

1. What are the rights of a data subjects?

A data subject may

• request access to his/her personal data, Article 15 GDPR
• request the rectification of incorrect personal data, Article 16 GDPR
• request the erasure of his/her personal data, Article 17 GDPR
• request the restriction of the processing of his/her personal data, Article 18 GDPR
• exercise the right to data portability, Article 20 GDPR
• object the processing of his/her personal data, Article 21 DSGVO

The aforementioned rights may be asserted against us, e.g. by providing notice to us via the contact details specified on the first page of this data protection information.

In case of further questions, you may also get in touch with our data protection coordinator.

In addition, the data subject is entitled to lodge a complaint regarding the handling of personal data with the competent supervisory authority, Article 77 GDPR.

***

Data protection information to our suppliers

We are committed to protect your personal data and comply with applicable data protection law, in particular the EU General Data Protection Directive («GDPR«) and, and we only process your personal data on the basis of a statutory provision or if the data subject has declared consent.

In this data protection information, we explain which information (including personal data) are processed by us in connection with the business relationship between you and us.

1. Who is responsible for the processing of personal data?

The controller responsible for the processing of personal data is URSA INSULATION, SA, Paseo de Recoletos, 3, 28004 Madrid. Any reference to «we» or «us» in this data protection information is a reference to the aforementioned entity.

Our data protection coordinator may be contacted via the aforementioned means or via privacy.ursa@etexgroup.com.

1. Which data do we process?

The performance of our business relationships requires the processing of data related to our customers. If this data concern a natural person (e.g. if you are a single trader and enter into a business relationship with us), it is considered as personal data. Regardless of the legal form of our contract partners, we process data concerning the contact persons acting for a customer.

Please make this data protection information available to the persons within your organization that are involved in the business relationship with us («contact persons«).

1. Basic data:We process certain general data concerning our customers and the contact persons as well as the business relationship with us, collectively «basic data».
   Basic data include:
   • any information provided to us in the course of establishing a business relationship or requested by us from our customers or a contact person (e.g., name, address and other contact details; and
   • any information collected and processed by us in connection with the establishment of the business relationship (e.g., the details of the agreements entered into)
2. Performance data:We process personal data collected in the course of the business relationship other than by merely updating basic data and that we refer to as «performance data».
   Performance data include:
   • Information on the performance of contractual obligations by our customers on the basis of the agreements entered into
   • Information on the performance of contractual obligations by us on the basis of the agreements entered into
   • Information provided by a customer or a contact person in the course of our business relationship, be it actively or upon our request; and
   • personal data that are provided to us in the course of our business relationship by our customer, a contact person or by third parties
3. To the extent permitted by law, we can add personal data provided by third parties to the aforementioned basic and performance data. Such data may include information regarding the commercial standing / rating of our customers if necessary for the assessment of financial risks (e.g. late payments). a) Information on the performance of contractual obligations by our customers on the basis of the agreements entered into.

III. For which purposes and on which legal basis do we process your personal data?

1. We process basic, performance and usage data for the performance of the contractual relationships with our customers or for pre-contractual measures on the basis of Article 6 para 1 b) GDPR. Regardless of the legal form of our customers, we process basic and performance data concerning one or more contact persons for the purpose of our justified interest in the performance of the business relationship on the basis of Article 6 para 1 f) GDPR.
2. We may process basic, performance and usage data also for compliance with legal obligations to which we are subject; this processing is based on Article 6 para 1 c) GDPR. Legal obligations may in particular include the mandatory disclosure of personal data to (tax) authorities.
3. To extent necessary, we process personal data (in addition to the processing for the purposes of the business relationship or to comply with legal obligations) for the purposes of our justified interests or the justified interests of a third party on the basis of Article 6 para 1 f) GDPR.
   Justified interest may include:
   • group-wide processes for internal administration of customer data
   • the establishment of or defence against legal claims
   • the prevention and investigation of criminal offences
   • maintenance of security for our information technology systems
   • the maintenance of security of our premises and infrastructure
   • management and further development of our business operations including risk management
4. If we provide to a natural person the option to declare a consent in the processing of personal data, we process the personal data covered by the consent for the purposes specified in such consent on the basis of Article 6 para 1 a) GDPR.
   Please note that the declaration of consent is voluntarily, that failure to declare consent or the withdrawal of a consent may, nevertheless, have consequences, and we will inform about such consequences before you are given the option to declare your consent consent may be withdrawn at any time with effect for the future, e.g. by providing notice to us via mail, fax, email using the contact information specified on the first page of this data protection notice.
5. Is there an obligation to provide personal data?

The provision of the basic and performance data specified in section II above is necessary for entering into and maintaining a business relationship with us, unless specified otherwise before or at collection of the data. Without the provision of these data, were are not able to enter into and maintain a business relationship.

If we collect additional data, we will indicate if the provision of such information is based on a legal or contractual obligation or necessary for the performance of an agreement. We usually indicate which information may be provided voluntarily and is neither based on a legal or contractual obligation nor necessary for the purposes of an agreement.

1. Who has access to personal data?

Personal data are generally processed within our company. Depending on the categories of personal data, only dedicated departments / organizational units are granted access to your personal data. Such units include in particular the Sale department and – if data are processed via our IT infrastructure – also our IT department. Based on a role / rights management concept, access to personal data is limited to the functions and the extent necessary for the respective purpose of the processing.

If and to the extent permitted by law, we may transfer your personal data to recipients outside of our company. Such external recipients may include affiliated companies within Etex group.

service providers that – on the basis of separate agreements with us – provide certain services possibly including the processing of personal data, as well as approved subcontractors of our service providers; private or public bodies, to the extent we are obliged to transfer your personal data on the basis of a legal obligation to which we are subject.

1. Do we use automated decision-making?

In the course of the business relationship we generally do not use automated decision-making (including profiling) within the meaning of Article 22 GDPR. If we apply such processes in the future, we will inform data subjects separately in accordance with the applicable statutory provisions.

VII. Are data transferred to countries outside the EU / the EEA?

Personal Information that we collect may be transferred to, and stored at, any of Etex’s affiliates and service providers in countries outside the EEA which do not necessarily offer an adequate level of protection of your Personal Data.

We comply with applicable legal requirements for the above transfer of your Personal Information, including the implementation of appropriate safeguards to ensure its protection. This implies reliance on specific derogations and safeguards set out in the GDPR, including the relevant standard contractual clauses.

VIII. How long are your data stored?

We generally store personal data as long as we have a justified interest in the retention of such data and there the interest of the data subject in refraining from the further processing do not prevail.

Even without a justified interest, we may continue to store the data if there is a legal obligation (e.g. to comply with statutory retention obligations). We delete personal data even without an action by the data subject as soon as further retention is no longer necessary for the purposes for which the data were collected or otherwise processed or if further retention is not permitted by law otherwise.

In general, basic data and the additional data collected in the course of the business relationship at least until the end of the respective business relationship. The data are deleted in any case if the purposes for the collection or processing were achieved. This point in time may be after the end of the business relationship with us. If personal data need to be stored to comply with a legal obligation, such data is retained until the end of the respective retention period. If personal data are only processed to comply with a statutory retention obligation, the access to such data is usually restricted so that the data are only accessible if needed for the purpose of the retention obligation.

1. What are the rights of a data subjects?

A data subject may

• request access to his/her personal data, Article 15 GDPR
• request the rectification of incorrect personal data, Article 16 GDPR
• request the erasure of his/her personal data, Article 17 GDPR
• request the restriction of the processing of his/her personal data, Article 18 GDPR;
  exercise the right to data portability, Article 20 GDPR
• object the processing of his/her personal data, Article 21 DSGVO.

The aforementioned rights may be asserted against us, e.g. by providing notice to us via the contact details specified on the first page of this data protection information.

In case of further questions, you may also get in touch with our data protection coordinator.

In addition, the data subject is entitled to lodge a complaint regarding the handling of personal data with the competent supervisory authority, Article 77 GDPR.

***

Data protection information to our employees

Processing of employee data

We are committed to protect your personal data and comply with applicable data protection law, in particular the EU General Data Protection Regulation («GDPR») and we only process your personal data on the basis of a statutory provision, your employment contract, or our legitimate interests, or if you have declared your consent.

In this data protection notice, we explain which information (including personal data) are processed by us in connection with your employment relationship.

1. Who is responsible for the processing of personal data?

The controller responsible for the processing of your personal data is URSA Insulation, S.A., Paseo de Recoletos, 3, 28004 Madrid, Spain, as your employer. Therefore, any reference to «we» or «us» in this data protection information is a reference to the aforementioned entity.

Our data protection coordinator may be contacted via the aforementioned means or via privacy.ursa@etexgroup.com.

1. Which data do we process?

The performance of your employment relationship requires the processing of personal data:

1. Basic data:We process certain general data in relation to your person and your employment relationship with us, collectively «basic data».
   Basic data include:
   • any information provided by you in the course of the recruitment process or that we requested from you (e.g., gender treatment, name, surname, address, telephone number, email address, date of birth, marital status, nationality, national identity card/ passport number, tax identification number, social security number, and information on your education and previous employment; and
   • any information stored in connection with our hiring decision (in particular the details of your employment agreement and information on your position and seniority within our organization).
2. Performance data:We process personal data collected in the course of your employment other than by merely updating your basic data and that we refer to as «performance data».
   Performance data include:
   • Information on the performance of your employee tasks, such as your work / absence times, skills, and the assessment of your performance, if applicable
   • Information on our performance of the employment relationship, such as our payments to you or other benefits or compensation, banking data, contribution bases, or taxes or contributions paid or payable on your behalf
   • Personal data provided to us in the course of your employment, either by you actively or upon our request, or by third parties (in particular public bodies such as social insurance bodies or (tax) authorities). This may include information on sick leave, pregnancy, the birth of a child, maternity leave, disabilities, a marriage or comparable changes of marital status.
3. Usage data:We process personal data collected in the course of your employment due to your use of our company infrastructure.
   Usage data include:
   • Information regarding your use of our information technology infrastructure (such as your business email account, internet access, landline and mobile services –data and voice-, or other applications, programs or devices provided to you); and
   • Information on your use of other company infrastructure such as infrastructure collecting user data when accessed by an employee, like connected machines or time management applications.
4. The aforementioned categories of data may include special categories of personal data in the sense of Article 9.1 GDPR, in particular
   • Health data (e.g., the information on your inability to work due to illness, or whenever there is a claim under the insurance policies contracted to insure the employees
   • Trade union membership data (only whenever this information is provided by you); and
   • Biometric data –photographs- (only whenever they are provided by you).

III. For which purposes and on which legal basis do we process your personal data?

1. We process basic, performance and usage data for the performance of your employment relationship with us on the basis of Article 6.1(b) GDPR.
2. We may process basic, performance and usage data also for compliance with legal obligations to which we are subject; this processing is based on Article 6.1(c) GDPR. Legal obligations may in particular include the mandatory disclosure of personal data to social insurance bodies and (tax) authorities, together with general retention mandatory provisions.
3. To the extent necessary, we process personal data (in addition to the processing for the purposes of the employment relationship or to comply with legal obligations) for the purposes of our justified interests or the justified interests of a third party on the basis of Article 6.1(f) GDPR.
   Justified interest may include:
   • group-wide processes for internal administration of employee data
   • the establishment of or defence against legal claims
   • the prevention and investigation of criminal offences
   • maintenance of security for our information technology systems
   • the maintenance of security of our premises and infrastructure
   • management and further development of our business operations including risk management
   • costs and headcount control within the Human Resources Department
   • filling of vacancies, promotion of employees or management of geographical and functional mobility
   • to obtain subsidies and subsidized financing of the available Public Aid Lines; and
   • recruitment and career development processes.
4. If the categories of data specified in section II above contain special categories of personal data (e.g. health data, trade union membership, biometric data), we process these data either for carrying out the obligations in the field of employment and social security and social protection law on the basis of Article 9.2(b) GDPR; on the basis of your making the data manifestly public according to Article 9.2.(e) GDPR; or for the establishment, exercise or defense of legal claims on the basis of Article 9.2(f) GDPR.
5. If we provide – during the recruitment process or in the course of the employment – the option to declare a consent in the processing of personal data, we process the personal data covered by your consent for the purposes specified in such consent on the basis of Article 6.1(a) GDPR. If the consent refers to special categories of personal data (such as health data), the processing is based on Article 9.2(a) GDPR.
   Please note that the declaration of your consent is always voluntarily, and neither the declaration of consent nor a later withdrawal of consent has negative consequences for the performance of your employment relationship; that failure to declare consent or the withdrawal of a consent may, nevertheless, have consequences, and we will inform you about such consequences before you are given the option to declare your consent; you may withdraw your consent at any time with effect for the future, e.g. by providing notice to us via mail, email using the contact information specified on the first page of this data protection notice.
6. Are you obliged to provide data?

The provision of the basic, performance and usage data specified in section II above is necessary for entering into and maintaining an employment relationship with us, unless specified otherwise before or at collection of the data. Without the provision of these data, were are not able to enter into and maintain an employment relationship with you.

If we collect additional data from you, we will inform you if the provision of such information is based on a legal or contractual obligation or necessary for the performance of an agreement (in particular your employment agreement). We usually indicate which information may be provided voluntarily and is neither based on a legal or contractual obligation nor necessary for the purposes of an agreement.

1. Who obtains or has access to your data?

Your personal data are generally processed within our company. Depending on the categories of personal data, only dedicated departments / organizational units are granted access to your personal data. Such units include in particular the HR department, your managers, the Legal department in case of establishment of or defence against legal claims, and – if data are processed via our IT infrastructure – also our IT department. Based on a role / rights management concept, access to personal data is limited to the functions and the extent necessary for the respective purpose of the processing.

If and to the extent permitted by law, we may transfer your personal data to recipients outside of our company. Such external recipients may include affiliated companies within Etex group, to which we may transfer personal data for internal administration of employee data; service providers that – on the basis of separate agreements with us – provide certain services possibly including the processing of personal data, as well as approved subcontractors of our service providers; private or public bodies, to the extent we are obliged to transfer your personal data on the basis of a legal obligation to which we are subject; and business partners, to the extent the transfer of personal data (e.g. your business contact details) is necessary for the performance of your employment relationshwip with us.

1. Do we use automated decision-making?

In the course of the recruitment process and the employment relationship we do not use automated decision-making (including profiling) within the meaning of Article 22 GDPR. If we apply such processes in the future, we will inform you separately in accordance with the applicable statutory provisions.

VII. Are data transferred to countries outside the EU / the EEA?

Personal Information that we collect may be transferred to, and stored at, any of Etex’s affiliates and service providers in countries outside the EEA which do not necessarily offer an adequate level of protection of your Personal Data.

We comply with applicable legal requirements for the above transfer of your Personal Information, including the implementation of appropriate safeguards to ensure its protection. This implies reliance on specific derogations and safeguards set out in the GDPR, including the relevant standard contractual clauses.

VIII. How long are your data stored?

We generally store your personal data as long as we have a justified interest in the retention of such data and there your interests in refraining from the further processing do not prevail.

Even without a justified interest, we may continue to store the data if there is a legal obligation (e.g. to comply with statutory retention obligations). We delete your personal data even without an action from your side as soon as further retention is no longer necessary for the purposes for which the data were collected or otherwise processed or if further retention is not permitted by law otherwise.

In general, your basic data and the additional data collected in the course of your employment are retained at least until the end of your employment. The data are deleted in any case if the purposes for the collection or processing were achieved. This point in time may be after the end of your employment relationship with us. If personal data need to be stored to comply with a legal obligation, such data is retained until the end of the respective retention period. If personal data are only processed to comply with a statutory retention obligation, the access to such data is usually restricted so that the data are only accessible if needed for the purpose of the retention obligation.

1. What are your rights as a data subject?

As a data subject, you may

• request access to your personal data, Article 15 GDPR
• request the rectification of incorrect personal data, Article 16 GDPR
• request the erasure of your personal data, Article 17 GDPR
• request the restriction of the processing of your personal data, Article 18 GDPR
• exercise your right to data portability, Article 20 GDPR
• object the processing of your personal data, Article 21 DSGVO.

The aforementioned rights may be asserted against us, e.g. by providing notice to us via the contact details specified on the first page of this data protection notice.

In case of further questions, you may also get in touch with our data protection coordinator.

In addition, you are entitled to lodge a complaint regarding the handling of your personal data with the competent supervisory authority, Article 77 GDPR.

***

Data protection information to our business partners

Processing of business partner data

We are committed to protect your personal data and comply with applicable data protection law, in particular the EU General Data Protection Directive («GDPR»), and we only process your personal data on the basis of a statutory provision or if the data subject has declared consent.

In this data protection information we inform you which information we process from our business partners. For the purpose of this data protection information business partners are to be those companies, function of persons, with which we do not have a contractual relationship regarding the delivery of our goods or the rendering of services, but with which we conduct nevertheless business contacts and relationships. These business contacts may be used for providing information about goods and services in single cases or also regularly. Business partners are for us i.e. official or private house builder, project developer, investors, architects, construction engineers, craftsmen and authorizes experts, who are involved in building projects or other projects, for which our products and services may be relevant (“projects”).

I.- Who is responsible for the processing of personal data?

The controller responsible for the processing of personal data is URSA INSULATION, SA, Paseo de Recoletos, 3, 28004 Madrid. Any reference to «we» or «us» in this data protection information is a reference to the aforementioned entity.

Our data protection coordinator may be contacted via the aforementioned means or via privacy.ursa@etexgroup.com.

II.- Which data do we process?

For the purposes of our business – namely for information about our products and services – we process data of our business partners. Insofar as these data allow conclusions to be drawn about a natural person (for example, if we process information about sole traders as business partners), these are personal data. Regardless of the legal form of our business partners, we also process data on the contact persons at our business partners.

Please make this data protection information available to the persons within your organization that are involved in the business relationship with us («contact persons»)

Basic data: We process certain general data concerning our business partners and the contact persons as well as the business relationship with us, collectively «basic data». Basic data include:

• all information about our business partner, which we ourselves or third parties can extract from publicly available sources about our business partner (such as name, address, other contact details and information about projects involving the respective business partner)
• the information provided to us by you or third parties working with you, if any, through a contact person (such as the details given on a business card given to us and the information provided to us in addition, such as a telephone call or telephone call) Meeting); as
• any information collected and processed by us in connection with the establishment of the business relationship (e.g., the details of the agreements entered into)

Performance data: We process personal data collected in the course of the business relationship other than by merely updating basic data and that we refer to as «performance data». Performance data include:

• information about the activities of our business partner (e.g. projects under involvement of our business partner), which we may extract ourselves or through third parties from publicly available sources
• information about the activity of our business partner, communicated to us by them or by third parties who work with them, possibly through a contact person
• Information about the projects planned or carried out with the participation of the respective business partner with regard to our products and services or the products and services of third parties.

III.- For which purposes and on which legal basis do we process your personal data?

We process basic, performance and usage data for the performance of the contractual relationships with our customers or for pre-contractual measures on the basis of Article 6 para 1 b) GDPR. Regardless of the legal form of our customers, we process basic and performance data concerning one or more contact persons for the purpose of our legitimate interest in the performance of the business relationship on the basis of Article 6 para 1 f) GDPR.

We may process basic, performance and usage data also for compliance with legal obligations to which we are subject; this processing is based on Article 6 para 1 c) GDPR. Legal obligations may in particular include the mandatory disclosure of personal data to (tax) authorities.

To extent necessary, we process personal data (in addition to the processing for the purposes of the business relationship or to comply with legal obligations) for the purposes of our legitimate interests or the legitimate interests of a third party on the basis of Article 6 para 1 f) GDPR. Legitimate interest may include group-wide processes for internal administration of customer data the establishment of or defense against legal claims the prevention and investigation of criminal offences maintenance of security for our information technology systems the maintenance of security of our premises and infrastructure management and further development of our business operations including risk management

If we provide to a natural person the option to declare a consent in the processing of personal data, we process the personal data covered by the consent for the purposes specified in such consent on the basis of Article 6 para 1 a) GDPR.

Please note that the declaration of consent is voluntarily, that failure to declare consent or the withdrawal of a consent may, nevertheless, have consequences, and we will inform about such consequences before you are given the option to declare your consent consent may be withdrawn at any time with effect for the future, e.g. by providing notice to us via mail, fax, email using the contact information specified on the first page of this data protection notice.

IV.- Is there an obligation to provide personal data?

The provision of the basic and performance data specified in section II above is necessary for entering into and maintaining a business relationship with us, unless specified otherwise before or at collection of the data. Without the provision of these data, were are not able to enter into and maintain a business relationship.

Please also note our advice on the right to object to the processing of personal data in order to safeguard legitimate interests in para. IX.

If we collect additional data, we will indicate if the provision of such information is based on a legal or contractual obligation or necessary for the performance of an agreement. We usually indicate which information may be provided voluntarily and is neither based on a legal or contractual obligation nor necessary for the purposes of an agreement.

V.- Who has access to personal data?​

Personal data are generally processed within our company. Depending on the categories of personal data, only dedicated departments / organizational units are granted access to your personal data. Such units include in particular the [#Sale department#] and – if data are processed via our IT infrastructure – also our IT department. Based on a role / rights management concept, access to personal data is limited to the functions and the extent necessary for the respective purpose of the processing.

If and to the extent permitted by law, we may transfer your personal data to recipients outside of our company. Such external recipients may include affiliated companies within Etex group, to which we may transfer personal data for the purpose of internal administration of employee data; other business partners to whom we may transfer personal information in order to safeguard the legitimate interests of the business partner to whom the data transmitted relates; service providers that – on the basis of separate agreements with us – provide certain services possibly including the processing of personal data, as well as approved subcontractors of our service providers; private or public bodies, to the extent we are obliged to transfer your personal data on the basis of a legal obligation to which we are subject.

VII.- Do we use automated decision-making?​

In the course of the business relationship we generally do not use automated decision-making (including profiling) within the meaning of Article 22 GDPR. If we apply such processes in the future, we will inform data subjects separately in accordance with the applicable statutory provisions.

VIII.- Are data transferred to countries outside the EU / the EEA?​

Personal Information that we collect may be transferred to, and stored at, any of Etex’s affiliates and service providers in countries outside the EEA which do not necessarily offer an adequate level of protection of your Personal Data.

We comply with applicable legal requirements for the above transfer of your Personal Information, including the implementation of appropriate safeguards to ensure its protection. This implies reliance on specific derogations and safeguards set out in the GDPR, including the relevant standard contractual clauses.

IX.- How long are your data stored?​

We generally store personal data as long as we have a justified interest in the retention of such data and there the interest of the data subject in refraining from the further processing do not prevail.

Even without a justified interest, we may continue to store the data if there is a legal obligation (e.g. to comply with statutory retention obligations). We delete personal data even without an action by the data subject as soon as further retention is no longer necessary for the purposes for which the data were collected or otherwise processed or if further retention is not permitted by law otherwise.

In general, basic data and the additional data collected in the course of the business relationship at least until the end of the respective business relationship. The data are deleted in any case if the purposes for the collection or processing were achieved. This point in time may be after the end of the business relationship with us. If personal data need to be stored to comply with a legal obligation, such data is retained until the end of the respective retention period. If personal data are only processed to comply with a statutory retention obligation, the access to such data is usually restricted so that the data are only accessible if needed for the purpose of the retention obligation.

X.- What rights does an data subject have?

Right of objection according to Art. 21 GDPR

An data subject has the right, at any time for reasons arising from your particular situation, to object to the processing of his/ her personal data relating pursuant to Article 6 (1) (e) or (f) GDPR; this also applies to a profiling based on these provisions. In the event of such objection, we will no longer process the personal data concerning that person, unless we can demonstrate compelling legitimate reasons for processing that outweigh the interests, rights and freedoms of the data subject, or the processing is for assertion, exercise or defense of legal claims.

When we process personal data to operate direct marketing, you have the right to object at any time to the processing of your personal data for the purposes of such advertising; this also applies to a profiling insofar as it is associated with such direct mail. If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

A data subject may

• request access to his/her personal data, Article 15 GDPR
• request the rectification of incorrect personal data, Article 16 GDPR
• request the erasure of his/her personal data, Article 17 GDPR
• request the restriction of the processing of his/her personal data, Article 18 GDPR
• exercise the right to data portability, Article 20 GDPR
• object the processing of his/her personal data, Article 21 DSGVO.

The aforementioned rights may be asserted against us, e.g. by providing notice to us via the contact details specified on the first page of this data protection information.

In case of further questions, the data subject may also approach our data protection officer.

In addition, the data subject is entitled to lodge a complaint regarding the handling of personal data with the competent supervisory authority, Article 77 GDPR.

***

Data protection information marketing

We are committed to protect your personal data and comply with applicable data protection law, in particular the EU General Data Protection Directive («GDPR») and, and we only process your personal data on the basis of a statutory provision or if the data subject has declared consent.

In this data protection information, we provide you with the mandatory information on the processing of your personal data. In relation to this processing, we comply with applicable data protection law, in particular the EU General Data Protection Regulation («GDPR«).

1. Who is responsible for the processing of personal data?

The controller responsible for the processing of personal data is URSA INSULATION, SA, Paseo de Recoletos, 3, 28004 Madrid. Any reference to «we» or «us» in this data protection information is a reference to the aforementioned entity.

Our data protection coordinator may be contacted via the aforementioned means or via privacy.ursa@etexgroup.com.

1. Which data do we process? For which purposes and on which legal basis do we process your personal data?

We would like to inform you about products, services, offers and promotions. For this purpose, we offer you the opportunity to choose between different contact channels when you give your consent.

Depending on your choice of one or more contact channels, we will process the necessary data as provided by you in the contact form, at least your surname and first name and the details of the contact channel (post, e-mail, telephone, SMS) selected by you.

We process this personal data on the basis of your consent and according to Article 6 (1) a) DSGVO

III. Is there an obligation to provide personal data? Can I withdraw my consent?

You give your consent and choose your contact channel on a purely voluntary basis. You are therefore not obliged to provide personal data. In order that we can send you the information via the desired contact channel, we require the data marked as mandatory fields in the contact form.

You can revoke your consent at any time without giving reasons with effect for the future by simply contacting us. You will also find a link to unsubscribe in each e-mail.

1. Who has access to personal data?

We will never sell your email address of other contact data to third parties. The data will only be transferred if this is necessary to send you our information. In this context, we can also commission external service providers and other group companys, taking into account the applicable statutory regulations.

We will only share your information with the following categories of recipients to prepare and send our information to you:

• Service providers within our group of companies (e.g. to provide statistical analysis and technical maintenance for our systems).
• External service providers who provide services on our behalf and on a separate contractual basis, such as collecting your data, hosting our websites, maintaining our call center, sending e-mails or written information or providing personal advice.

In addition, we may transfer data to other recipients (e.g. public authorities) to the extent we are obliged to transfer your personal data on the basis of a legal obligation to which we are subject

1. Do we use automated decision-making?

In the course of our direct marketing activities we generally do not use automated decision-making (including profiling) within the meaning of Article 22 GDPR. If we apply such processes in the future, we will inform data subjects separately in accordance with the applicable statutory provisions.

1. Are data transferred to countries outside the EU / the EEA?

Personal Information that we collect may be transferred to, and stored at, any of Etex’s affiliates and service providers in countries outside the EEA which do not necessarily offer an adequate level of protection of your Personal Data.

We comply with applicable legal requirements for the above transfer of your Personal Information, including the implementation of appropriate safeguards to ensure its protection. This implies reliance on specific derogations and safeguards set out in the GDPR, including the relevant standard contractual clauses.

VII. How long are your data stored?

1. We generally store personal data as long as we have a justified interest in the retention of such data and there the interest of the data subject in refraining from the further processing do not prevail. Even without a justified interest, we may continue to store the data if there is a legal obligation (e.g. to comply with statutory retention obligations). We delete personal data even without an action by the data subject as soon as further retention is no longer necessary for the purposes for which the data were collected or otherwise processed or if further retention is not permitted by law otherwise.
2. As far as the aforementioned processing is concerned, we will store your personal data as long as you have not withdrawn your consent or indicated otherwise that you do not want to be provided with further information from us. Also in this case, we store your contact data in order to ensure that you are not contacted following your withdrawal or objection (so called blacklist).
3. If personal data need to be stored to comply with a legal obligation, such data is retained until the end of the respective retention period. If personal data are only processed to comply with a statutory retention obligation, the access to such data is usually restricted so that the data are only accessible if needed for the purpose of the retention obligation.

VIII. What are your rights as a data subject?

As a data subject you may

• request access to your personal data, Article 15 GDPR
• request the rectification of incorrect personal data, Article 16 GDPR
• request the erasure of your personal data, Article 17 GDPR
• request the restriction of the processing of your personal data, Article 18 GDPR
• exercise the right to data portability, Article 20 GDPR
• object the processing of your personal data, Article 21 DSGVO.

The aforementioned rights may be asserted against us, e.g. by providing notice to us via the contact details specified on the first page of this data protection information.

In case of further questions, you may also get in touch with our data protection coordinator by sending an e-mail to: privacy@ursa.com.

In addition, the data subject is entitled to lodge a complaint regarding the handling of personal data with the competent supervisory authority, Article 77 GDPR.

***

Data Protection Information job applicants data

We are committed to protect your personal data contained in your curriculum vitae (CV) and to comply with applicable data protection law, in particular, the EU General Data Protection Regulation («GDPR«) and we only process your personal data on the basis of a statutory provision or if you have declared your consent.

In this data protection notice, we explain which information (including personal data) is processed by us once we have received your CV in the “career section” of our web page www.ursa.com or at the reception desk of our premises.

1. Who is responsible for the processing of personal data?

The controller responsible for the processing of your personal data is Ursa Insulation, S.A., Paseo de Recoletos, 3, 28004 Madrid, Spain (hereinafter, Ursa). Therefore, any reference to «we» or «us» in this data protection information is a reference to the aforementioned entity.

Our data protection coordinator may be contacted via the aforementioned means or via privacy.ursa@etexgroup.com.

1. Which data do we process?

The storage and use of your CV for future recruitment processes requires the processing of the personal data contained in your CV. This treatment will be «automated» for CVs received through the “career section” of our web page and «not automated» for CVs received at our facilities in paper format.

Ursa will process any information you have included in the web form and in your CV – in general, gender treatment, name, surname, address, telephone number, email address, date of birth, marital status, nationality, national identity card/ passport number, information on your education and previous employment, and aspects of personality, behavior or skills. The preceding categories of data may include special categories of personal data in the sense of Article 9.1 GDPR, such as your photograph, only whenever they are provided by you.

III. For which purposes and on which legal basis do we process your personal data?

We process the data contained in the “career section” and in your CV to keep you informed of the different job vacancies in our organization, as well as to evaluate you as a candidate in our personnel selection processes.

We process your data on the basis of Article 6.1(a) GDPR, i.e., on the basis of your consent. If the consent refers to special categories of personal data (such as health data), the processing is based on Article 9.2(a) GDPR.

Please note that the declaration of your consent is always voluntary. However, your lack of consent will make it impossible for us to keep your CV and process any of the personal data included in it. You may withdraw your consent at any time with effect for the future, e.g. by providing notice to us via mail or email using the contact information specified in the first section of this data protection notice.

1. Are you obliged to provide data?

The provision of the data contained in your CV is necessary for storing the same and use the data within the context of future recruitment processes in our company. Without the provision of these data, were will not able to use your CV future recruitment processes.

1. Who obtains or has access to your data?

Your personal data are generally processed within our company and particularly by our Human Resources Department. The department concerned by the selection process may have access to your personal data as well.

If and to the extent permitted by law, we may transfer your personal data to recipients outside of our company. Such external recipients may include

• affiliated companies within the Etex group, which Ursa belongs to;
• recruitment services providers; and
• private or public bodies, to the extent we are obliged to transfer your personal data on the basis of a legal obligation to which we are subject.

1. Do we use automated decision-making?

In the course of the recruitment process and the employment relationship, we do not use automated decision-making (including profiling) within the meaning of Article 22 GDPR. If we apply such processes in the future, we will inform you separately in accordance with the applicable statutory provisions.

VII. Are data transferred to countries outside the EU / the EEA?

Personal Information that we collect may be transferred to, and stored at, any of Etex’s affiliates and service providers in countries outside the EEA which do not necessarily offer an adequate level of protection of your Personal Data.

We comply with applicable legal requirements for the above transfer of your Personal Information, including the implementation of appropriate safeguards to ensure its protection. This implies reliance on specific derogations and safeguards set out in the GDPR, including the relevant standard contractual clauses.

VIII. How long are your data stored?

We keep personal data for a maximum of one year after receiving your CV.

We will cease to keep your personal data at the end of this maximum period unless you inform us before that date of your interest in the cessation of such processing by our company. In addition, we delete your personal data as soon as further retention is no longer necessary for the purposes for which the data were collected or otherwise processed or if further retention is not permitted by law otherwise.

In the event that the applicant is finally selected to become a member of the Ursa workforce, we inform you that we will keep and process the personal data contained in your CV for the entire duration of the employment relationship, except in the event that the personal data need to be stored beyond that time to comply with a legal obligation, in which case such data is retained until the end of the respective legal retention period.

1. What are your rights as a data subject?

As a data subject, you may

• request access to your personal data, Article 15 GDPR;
• request the rectification of incorrect personal data, Article 16 GDPR;
• request the erasure of your personal data, Article 17 GDPR;
• request the restriction of the processing of your personal data, Article 18 GDPR;
• exercise your right to data portability, Article 20 GDPR;
• object the processing of your personal data, Article 21 GDPR.

The aforementioned rights may be asserted against us, e.g. by providing notice to us via the contact details specified on the first section of this data protection information notice, sheet, together with a copy of your Identity Card or equivalent identification document. In case of further questions, you may also get in touch with our data protection coordinator by sending an email to via privacy.ursa@etexgroup.com.

In addition, if you consider that your data are not correctly treated by our company or that your requests to exercise rights have not been satisfactorily attended, you are entitled to lodge a complaint regarding the handling of your personal data with the competent supervisory authority, Article 77 GDPR.

1. Personal data security and confidentiality

In order to safeguard the security of your personal data, we inform you that Ursa has adopted all the necessary technical and organizational measures to guarantee the protection of the personal data provided. All of the foregoing aimed at avoiding their alteration, loss, and/or unauthorized processing or access, as required by law.

We inform you that your data will be treated with the maximum confidentiality by all the personnel involved in any of the phases of the treatment.

***