In compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter GDPR), Sircat Recycling S.L. (hereinafter SIRCAT) discloses the present Policy regarding the processing and protection of personal data.

Data of the person in charge of the treatment

Sircat Recycling S.L.

TAX ID: B-61794962

Registered office: Calle Puig i Cadafalch, núm. 17, 08191 de Rubí (Barcelona).

E-mail: info@Sircat.net

Scope of application

This Policy shall apply:

• To those persons who visit the SIRCAT website, www.Sircat.net (hereinafter, any reference to it shall also include the Catalan, English and Spanish versions).
• To those who voluntarily communicate with SIRCAT via e-mail or who fill out any of the data collection forms published on the SIRCAT website.
• To those who request information about SIRCAT’s products and services or who request to participate in any of SIRCAT’s commercial actions.
• To those who formalize a contractual relationship with SIRCAT by contracting its products and services.
• To those who use any other service present on the website that involves the communication of data to SIRCAT or access to data by SIRCAT for the provision of its services.
• To any others who, directly or indirectly, have given their express consent for their data to be processed by SIRCAT for any of the purposes set out in this Policy.

The use of SIRCAT products and services requires the express acceptance of this Policy.

SIRCAT warns that, except for the existence of a legally constituted representation, no user and/or client can use the identity of another person and communicate their personal data, so the data provided to SIRCAT must be personal data, corresponding to their own identity, adequate, relevant, current, accurate and true.
In this sense, the user and/or client will be solely responsible for any direct or indirect damage caused to third parties or SIRCAT by the use of data of another person or their own data when they are false, erroneous, not current, inadequate or irrelevant.
Likewise, the user and/or client who communicates the personal data of a third party will be responsible for having obtained the corresponding authorization from the interested party, as well as for the consequences if this is not the case.

Similarly, the user and/or client who communicates personal data to SIRCAT declares to be of legal age, in accordance with the provisions of Spanish law, refraining otherwise from providing data to SIRCAT.
Any data provided about a minor will require the consent or prior authorization of their parents, guardians or legal representatives, who will be considered responsible for the data provided by the minors in their care.

This Policy will be of subsidiary application with respect to those other conditions on personal data protection that are established with special character and are communicated, without limitation, through the registration forms, contracts and/or conditions of the particular services, being therefore this Policy complementary to those mentioned in what is not expressly foreseen in the same.

Purposes of the collection and processing of personal data

SIRCAT, in its capacity as data controller, informs users of the existence of several processing and files in which personal data communicated to SIRCAT are collected and stored.

The purposes of such collection and processing of personal data are as follows:

• Regarding the “cookies” that SIRCAT uses in the navigation through its web pages (http://www.Sircat.net/), are stored in the user’s terminal equipment (computer or mobile device) and collect information when visiting these web pages, in order to improve the usability of the same, to know the habits or browsing needs of users in order to adapt to them, as well as to obtain information for statistical purposes.
  In the case of those users who are already SIRCAT customers, the information collected with the cookies will also be used to identify them when accessing the different tools that SIRCAT makes available to them for the management of the services.
  In any case, users can configure their browser to disable or block the reception of all or some of the cookies.
  The fact of not wishing to receive these cookies does not constitute an impediment to access the information on the SIRCAT websites, although the use of some services may be limited.
  If once the consent for the reception of cookies has been granted, it is desired to withdraw it, those stored in the user’s equipment must be eliminated, through the options of the different browsers.
• All the information about the cookies used by SIRCAT is published in its Cookies Policy, available for consultation at: http://www.Sircat.net/index.php/es/politicas-legales/politica-privacidad
• In the case of sending an e-mail to SIRCAT or a communication of personal data through any other means, such as a contact form, the purpose of the collection and processing of such data by SIRCAT is the attention of queries and requests for information that arise about the products and services of SIRCAT.
• In the case of sending an e-mail to SIRCAT related to its job offers, such data will be processed in order to participate in personnel selection procedures.
• In the case of SIRCAT forms that the interested parties fill in to participate in any of SIRCAT’s commercial actions, the purpose will be to enable such participation, as well as the sending of commercial and advertising communications about SIRCAT’s services, unless the interested party expressly states its opposition at the same time of the collection of its data.
  Notwithstanding the above, the interested party may modify his or her decision at any time, as many times as he or she wishes, through the means provided by SIRCAT for this purpose.
• When contracting the services offered by SIRCAT, only those personal data will be collected that are necessary to establish the contractual relationship and enable the provision of services and remuneration thereof by customers, being such data collected and processed for the following purposes:
• The main purpose will consist of maintaining the contractual relationship established with the customer, in accordance with the nature and characteristics of the services contracted, contacting SIRCAT with the customer through the e-mail address, telephone or other means indicated by the latter.
• For the sending of documentation and information related to the contracted services, as well as for the sending of commercial and advertising communications about the same or similar by SIRCAT, through postal mail, e-mail, telephone, SMS or other means indicated by the client, unless the client expressly states his opposition at the same time of contracting.
  Regardless of whether or not the client has chosen to receive commercial information from SIRCAT, the client may modify his decision at any time, as many times as he wishes, through the specific section available for this purpose in his Client Area.
• For the maintenance of historical records of commercial relations during the legally established periods.
• In those cases in which SIRCAT must access and/or process personal data for which the customer has the status of data controller or data processor, SIRCAT will process such data as data processor in accordance with the provisions of Article 28 of the GDPR and as indicated in the section entitled “SIRCAT as data processor”, included in this Policy.
• For all other purposes expressly stated in the Specific Conditions applicable to the corresponding product or service contracted by the customer and expressly accepted by the customer.

Time period for the conservation of personal data

SIRCAT will keep the personal data for the time strictly necessary for the fulfillment of the purposes detailed above.
SIRCAT may keep such data duly blocked during the period in which liabilities may arise from its relationship with the customer.

In the case of data subject to conservation in accordance with Law 25/2007, of October 18, 2007, on the conservation of data relating to electronic communications and public communications networks, the conservation period will be as detailed in the aforementioned regulations.

Recipients of personal data

The recipients of the personal data collected by SIRCAT will be the following:

• SIRCAT’s own employees in the performance of their duties.
• SIRCAT suppliers involved in the provision of the services, in the event that this is necessary for the provision of the services.
• Companies belonging to the Group of Companies of which SIRCAT forms part, understood in the sense of article 42 of the Code of Commerce, whose activity is the commercialization of services of identical or analogous nature offered by SIRCAT, such as waste collection, management or treatment services.
• The judicial or administrative bodies, as well as the State Security Forces and Corps, in the event that SIRCAT is required under current legislation to provide information related to its customers and services.
• Any others that due to the nature of the service must access the data provided with the same, as detailed in the Specific Conditions that are applicable to the corresponding product or service contracted by the customer and expressly accepted by the customer.

User rights and the exercise of these rights

Users may exercise at any time the following rights recognized by the RGPD:

• Right of access.
  Users have the right to obtain from SIRCAT information about whether personal data concerning them are being processed, to access them and to obtain information about the processing carried out.
• Right to obtain a copy of your personal data.
• Right of rectification.
  Users have the right to have SIRCAT rectify their personal data if it is inaccurate or incomplete.
• Right of deletion. Users have the right to proceed to the deletion of data when they are no longer necessary for the purpose for which they were provided or when the other circumstances provided by law.
• Right to limitation of processing. Users have the right to request a limitation in the processing of their personal data, so that the processing operations that should correspond in each case are not applied to them, in those cases provided for in art. 18 of the RGPD.
• Right to portability. Users have the right to receive personal data concerning them in a structured format, provided that such data pertain exclusively to the user and have been provided by the user.

Users, whether they are SIRCAT customers or not, may exercise these rights by sending a communication by e-mail to the following address info@Sircat.net or by sending a request accompanied by your ID card or valid document proving your identity, addressed to SIRCAT, S.L. C/ Puig i Cadafalch 17, 08191 Rubí (Barcelona) Spain, to the attention of the Commercial Department, specifying the right you wish to exercise.

In cases of manifestly unfounded or excessive requests due to their repetitive nature, SIRCAT reserves the right to charge a fee for the administrative costs arising or the right to refuse to act on them, in accordance with the provisions of art. 12.5 RGPD.

Supervisory authority

Users and/or customers may contact the appropriate local supervisory authority if they consider that the processing of their personal data has not been carried out in accordance with the legislation in force.

The data protection supervisory authority in Spain is the Spanish Data Protection Agency, whose contact details are available on its website, specifically at. http://www.agpd.es/portalwebAGPD/CanalDelCiudadano/contacteciudadano/index-ides-idphp.php.

International data transfers

In those products and services of SIRCAT in which international transfers are required to enable the provision of these, this circumstance will be included in the Specific Conditions that apply to the corresponding product or service contracted by the customer and expressly accepted by the customer prior to the same.

SIRCAT as data processor

Pursuant to article 28 RGPD and concordant, SIRCAT will process the personal data for which the client will be responsible or in charge of the processing, when it is necessary for the proper provision of the contracted services.
In this case, SIRCAT will act as data processor, according to the terms indicated below:

• SIRCAT will only process the data in accordance with the instructions of the customer responsible or in charge of the processing, not using them for a purpose other than that contained in this Data Protection Policy and/or in the contractual conditions that are applicable.
• Once the services that motivate the processing of personal data have been provided, they will be destroyed, as well as any support or documents containing any personal data or any type of information that has been generated during, for and/or due to the provision of the services that are the object of the corresponding Conditions.
  Notwithstanding the above, SIRCAT may keep such data duly blocked during the period in which liabilities may arise from its relationship with the client.
• In the event that SIRCAT uses the data for another purpose or communicates or uses them in breach of this Data Protection Policy and/or the corresponding Terms of Service, it will also be considered responsible for the processing.
• SIRCAT undertakes, in accordance with Article 28 of the RGPD, to maintain due professional secrecy with respect to the personal data to which it must access and/or process in order to comply in each case with the object of the Terms of Service applicable to it, both during and after the termination of the same, undertaking to use such information only for the purpose intended in each case and to require the same level of commitment from any person within its organization involved in any phase of the processing of the personal data for which the customer is responsible.
• In accordance with the provisions of the RGPD, the following rules shall apply in relation to the form and modalities of access to data for the provision of services:
  • In the event that SIRCAT must access the processing resources located at the client’s premises, the client shall be responsible for establishing and implementing the security policy and measures, as well as for communicating them to SIRCAT, who undertakes to respect them and to require compliance with them by the persons in its organization who participate in the provision of the services.
  • When SIRCAT remotely accesses the customer’s data processing resources, the customer shall establish and implement the security policy and measures in its remote processing systems, being SIRCAT responsible for establishing and implementing the security policy and measures in its own local systems.
  • When the service is provided by SIRCAT in its own premises, SIRCAT will record in its Register of activities the circumstances relating to the processing of data in the terms required by the RGPD, including the security measures corresponding to such processing.

• The client authorizes SIRCAT, in its capacity as data processor, to subcontract with third parties, in the name and on behalf of the client, the services of storage, custody of backup copies of data and security, and those that were necessary to enable the provision of contracted services, respecting in any case the obligations imposed by the RGPD and its implementing regulations.
  At any time, the client may contact SIRCAT to know the identity of the subcontracted entities for the provision of the services indicated, which will act in accordance with the terms provided in this document and after formalization with SIRCAT of a data processing contract in accordance with art. 28.4 of the RGPD.

• The client authorizes SIRCAT to perform the actions listed below, provided that they are necessary for the execution of the provision of the services.
  Such authorization is limited to the action/s necessary for the provision of each service and with a maximum duration linked to the term of the applicable Contractual Conditions:
  • To carry out the processing of personal data on portable devices only by users or user profiles assigned to the provision of services.
  • To carry out the processing outside the client’s or SIRCAT’s premises, only by the users or user profiles assigned to the provision of the services.
  • The entry and exit of media and documents containing personal data, including those included in and/or attached to an e-mail, outside the premises under the control of the customer responsible for the processing.
  • The execution of data recovery procedures that SIRCAT is obliged to carry out.
• SIRCAT is not responsible for the breach of the obligations arising from the RGPD or the corresponding regulations on data protection by the user and / or customer in relation to its activity and that is related to the execution of the contract or business relationships that bind you to SIRCAT.
  Each party shall face the liability arising from its own breach of contractual obligations and the regulations themselves.