1. Who is responsible for processing your data?
AGUIRREGOMEZCORTA Y MENDICUTE, S.A
Tax ID (CIF): ES A20022448
APALATEGI 7 - 20600 - EIBAR – GIPUZKOA - SPAIN
Phone: +34 943 121 608 · Email: agme@agme.net
Data Protection Officer (DPO): appointing a DPO is not mandatory under Article 37 GDPR, given the volume and nature of the processing carried out. For any question relating to data protection, or to exercise your rights, you may contact privacidad@agme.net.
2. For what purpose do we process your personal data?
At AGUIRREGOMEZCORTA Y MENDICUTE, S.A. we process the personal data provided to us by data subjects for the following purposes, depending on the channel through which it is collected:
- a) Responding to information requests: when you contact us through our contact form, we handle your enquiry, respond to you and, where applicable, manage the commercial, administrative, accounting and tax aspects of the services requested.
- b) Sending commercial communications (newsletter): when you voluntarily subscribe to our newsletter, we send you information about our products and services by email, only if you have given your express and separate consent to do so.
- c) Unsolicited applications: AGME does not publish job vacancies on its website. When you send us your CV on your own initiative, whether by email or through our contact form, we process your data solely to assess your application for possible future selection processes.
3. How long will we keep your data?
- Information requests: we keep the data for as long as necessary to handle your enquiry and, if a business relationship arises from it, for as long as that relationship continues; afterwards, for the statutory limitation periods applicable (tax, commercial).
- Newsletter: we keep the data until you unsubscribe. You may unsubscribe at any time via the link included in each communication or by writing to privacidad@agme.net.
- Unsolicited applications: we keep the data for a maximum of 1 year from receipt. After that period the data will be deleted, unless you expressly authorise us to keep it for future selection processes.
4. What is the legal basis for processing your data?
We indicate below the legal basis for processing your data:
- Performance of a contract / pre-contractual measures taken at the request of the data subject: handling your enquiry and providing the services requested.
- Consent of the data subject (Art. 6(1)(a) GDPR and Art. 21 LSSICE): sending commercial communications by electronic means (newsletter). This consent is freely given, specific, informed and unambiguous, and may be withdrawn at any time without affecting prior processing.
- Consent of the data subject (Art. 6(1)(a) GDPR): the voluntary submission of your CV, on your own initiative and without a published vacancy, implies your consent for your data to be processed for the purpose of assessing your application.
5. Who will your data be shared with?
Where the enquiry or information request received corresponds to the area of a commercial agent or representative — in Spain or abroad — your data is shared with that agent or representative, solely so that they can handle your request and manage the commercial contact for their area.
In addition, certain technology providers that provide web hosting and/or electronic communication services (processors) may access the data solely to provide those services, under the corresponding data processing agreement (Art. 28 GDPR).
CVs received are handled internally by AGME staff responsible for recruitment; they are not shared with third parties, except where legally required.
6. Transfers of data to third countries
Where the commercial agent or representative who must handle your request is located outside the European Economic Area, your data is transferred to that agent solely to handle your information request and manage the commercial contact in their area. This transfer is covered by standard contractual clauses for data protection approved by the European Commission, signed with our international agents.
The countries in which our international representatives and distributors operate can be found on the "Global presence" page of this website: agme.net/es/agme/presencia-global/red-de-distribucion-internacional.
7. What are your rights when you provide us with your data
Anyone has the right to obtain confirmation as to whether AGUIRREGOMEZCORTA Y MENDICUTE, S.A. is processing personal data concerning them, or not.
Data subjects have the right to access their personal data, as well as to request rectification of inaccurate data or, where applicable, request its erasure when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
In certain circumstances, data subjects may request the restriction of the processing of their data, in which case we will only keep it for the establishment, exercise or defence of claims.
In certain circumstances and for reasons relating to their particular situation, data subjects may object to the processing of their data. In this case, AGUIRREGOMEZCORTA Y MENDICUTE, S.A. will stop processing the data, except for compelling legitimate grounds, or for the establishment, exercise or defence of claims.
You may exercise your rights by contacting the data controller's address.
If you have given your consent for a specific purpose, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. If you have given your consent to receive the newsletter, you may unsubscribe at any time by clicking the unsubscribe link included in each communication, or by writing to privacidad@agme.net, without having to justify your decision.
If you feel that your data protection rights have been violated, particularly when you have not obtained satisfaction in exercising your rights, you may file a complaint with the competent Data Protection Supervisory Authority through its website: www.aepd.es
8. How did we obtain your data?
The personal data we process at AGUIRREGOMEZCORTA Y MENDICUTE, S.A. comes directly from the data subject or from commercial distributors.
The categories of data processed are:
- Identification data
- Postal and email addresses
- Commercial information
We do not process special categories of personal data (data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a person's sex life or sexual orientation).
9. Security measures
AGUIRREGOMEZCORTA Y MENDICUTE, S.A. applies appropriate technical and organisational measures to ensure a level of security appropriate to the risk of the processing, in accordance with Article 32 GDPR.
10. Minors
The forms on this website are aimed at adults in the context of business-to-business (B2B) commercial relationships. We do not knowingly collect data from minors under 14 years of age.
11. Video surveillance
AGUIRREGOMEZCORTA Y MENDICUTE, S.A. has a video camera system on the outside of its premises. We inform you of the following:
- Purpose: to ensure the security of people, property and facilities.
- Legal basis: legitimate interest of the data controller (Art. 6(1)(f) GDPR), under the terms enabled by Article 22 of Organic Law 3/2018 (LOPDGDD) for the use of camera or video camera systems for security purposes.
- Retention period: a maximum of one month from recording, unless the images need to be kept to provide evidence of acts against the integrity of people, property or facilities, in which case the images will remain available to the competent authority.
- Recipients: our video surveillance installation and maintenance provider, who may remotely access recordings for technical support purposes, as a data processor (Art. 28 GDPR); and law enforcement authorities, in the event of an incident.
- Rights: you may exercise your rights of access, rectification, erasure, objection, restriction and portability by contacting privacidad@agme.net, as well as filing a complaint with the AEPD (www.aepd.es).