TRIFERMED wishes to provide users of our website www.trifermed.com (hereinafter, the “Website”) and our clients (hereinafter, and all together “Data Subjects”) with this extended privacy policy (hereinafter, “Privacy Policy”) where we share in a transparent and simple way all the information about the processing that we perform with your personal data, the purposes of those processing and the rights that Data Subjects may exercise. This Privacy Policy will always be available in our Website.

1. WHO ARE WE AND HOW YOU CAN CONTACT US?

The entity responsible for the personal data processing is TRIFERMED, S.L. (hereinafter, “TRIFERMED”), constituted according to the Spanish Laws, addressed in Paseo Antoni Gaudí 8-B, 08172 Sant Cugat del Vallès (Barcelona), holder of the CIF number B-62.917.141 and registered in the Mercantile Register of Barcelona in volume 43103, sheet 27, page B-248259. 

If you have any questions about the processing we carry out of your personal data, you can contact us via email: info@trifermed.com

2. WHAT IS A PERSONAL DATA AND WHAT IS A PROCESSING OF PERSONAL DATA?

Personal data is any information about an identified or identifiable natural person. Any person whose identity can be determined, directly or indirectly, in particular by an identifier, such as a name, an identification number, location data, an online identifier or one or more elements of that person’s physical, physiological, genetic, psychic, economic, cultural or social identity that permits the identification of a natural person. The processing of personal data is any operation or set of operations that we carry out on your personal data, such as the collection, registration, retention, use and communication of your data.

3. HOW CAN WE COLLECT PERSONAL DATA FROM YOU?

We may collect personal data about you through the following ways: 

  • By registering and assisting to the Trifermed Awards;
  • By sending us your CV;
  • By the execution of the contract between Trifermed and the Client; and
  • By contacting us at the email addresses or telephone numbers available on our Website.

3. WHAT RIGHTS CAN YOU EXERCISE?

A) Right of access

You have the right to know if TRIFERMED is processing your personal data and, if so, to know what personal data is being processed.

B) Right of rectification

You have the right to modify your personal data if it is inaccurate or incomplete. To do this you must indicate what personal data you want to rectify and prove them appropriately.

C) Right to object

In the legally contemplated cases you can object at any time, for reasons related to your situation, to our processing of your data. Nonetheless, when the processing is based on your consent or in the execution of a contractual relationship, the objection to the processing will imply the impossibility for TRIFERMED to comply with the purpose of the processing or to execute the contract. 

D) Right to erasure

You have the right to erase your personal data. This does not mean that your data is completely deleted, but that your data will be kept blocked in such a way as to prevent its processing, without prejudice to the possibility of making it available to public administrations, judges and courts for the attention of possible responsibilities that have arisen as a result of the treatment during the limitation period of the latter.

E) Right to portability

You have the right to receive and/or transfer to another controller different to TRIFERMED the personal data that concerns you and that you have provided to us.

F) Right of restriction of processing

You have the right to ask us to suspend the processing of your data when (i) you have challenged the accuracy of your data, while TRIFERMED verifies such accuracy; or (ii) you have exercised your right to object to the processing of your data, while verifying whether TRIFERMED’s legitimate reasons prevail over yours as a data subject. Likewise, this right allows you to ask TRIFERMED to keep your personal data when (i) the processing of data is unlawful and as a data subject you object to the deletion of your data, requesting instead a limitation of its use; or (ii) TRIFERMED no longer needs your personal data for the purposes of the processing, but needs it for the formulation, exercise, or defence of claims.

You can exercise your rights by sending us your request to the following email address info@trifermed.com, identifying yourself. We also inform you that, in the event that you consider that we do not have properly satisfied the exercise of your rights, you can file a complaint with the Spanish Data Protection Agency (AEPD) by its website http://www.aepd.es

5. PROCESSING OF YOUR PERSONAL DATA

In order to be able to inform you in a transparent and detailed way about the purposes for which we process your personal data we have proceeded to separate the information related to each processing into separate tables. Thus, you can find all the specific information about each of the processing we carry out of your personal data in its corresponding table individually. Each descriptive table of the corresponding processing contains the following information:

For what purposes do we process your personal data?

In this column we explain for what purposes do we process your personal data.

On what legal basis do we process your personal data?

This column explains the legal basis or justification that allows us to process your personal data lawfully. Data protection regulation require us to process your data on a legal basis or justification that legitimizes such processing. Thus, to process your personal information we may rely on different bases or legal justifications depending on the processing we carry out of your data. The legal bases for the processing of your personal data may be: 

  • Legitimate interest: TRIFERMED may have a legitimate interest in performing certain processing of the personal data. In any case, this legitimate interest is based on an analysis of the proper balance of our interests in processing your personal data and your rights and freedoms. The result of such analysis will determine whether we may use your personal information for the processing described in this Privacy Policy. 
  • Fulfilment of a legal obligation: TRIFERMED acts as responsible for the personal data of the Data Subjects and must comply with a series of obligations imposed by accounting, tax, commercial regulations, crime prevention, etc. In cases where the legal justification for the processing of personal data is compliance with a legal obligation, the Data Subjects may not object to its processing. 
  • Your consent: In the event that TRIFERMED wishes to carry out any processing of your data whose legal justification cannot be based on any of the reasons explained above, we will request your consent prior to such processing. In any case, we will inform you duly in advance of all aspects derived from such processing and you can always withdraw your consent once you have provided it. 

What personal data do we collect from you?

In order to carry out the personal data processing that we specify in this Privacy Policy, we need to collect certain information about the users of our Website. Therefore, we collect the information provided to us by users through TRIFERMED’s different channels of interaction and communication for each data processing. 

How long do we keep personal data?

This column provides guidance for how long data will be retained. The storage time will depend in any case on the processing carried out on the personal information. Please note that certain accounting, tax and data protection regulations, among others, may require us to retain certain data of Data Subjects for a certain period of time.

You will find described in more detail the different personal data processing carried out by TRIFERMED in the following sections:

1. Management of the relation with the Clients

For what purposes do we process your data?Which is the legal basis for the processing of your data?What personal data do we collect from you?How long will we keep your personal data?
Execute the contract between TRIFERMED and the Client. Manage any incidence that can arise because of the contractual relation. Comply with all legal obligations demanded to TRIFERMED.  Provide a Customer Support Service answering to any question or information request. 
Satisfying the legitimate interest followed by the Client for complying with the contract enforced by the Client and TRIFERMEDName and surname DNI, NIE or Passport Job position and employing company.  Telephone number and email address. We will retain the personal data for as long as the contract between the Client and TRIFERMED is in force, or until the Data Subject exercise his suppression right. Once the relation with the Client is finished, TRIFERMED will keep the personal data duly blocked for the limitation on actions. Once the maximum period of data processing has arrived, TRIFERMED will anonymize or delete the personal data of the Data Subjects.

2. Manage the assistance of the Data Subjects to the Trifermed Awards

For what purposes do we process your data?Which is the legal basis for the processing of your data?What personal data do we collect from you?How long will we keep your personal data?
Manage the registration and the assistance for the Trifermed Awards.  Guarantee the adequate development of the event.  Manage any incidence related to the registration for the Trifermed Awards. Express consent that the user provides to TRIFERMED by registering to the Trifermed Awards through the available form on the Website. Name and surname EmailPersonal data will be processed by TRIFERMED until Trifermed Awards are over, or until the user request the erasure or objection of the processing of his/her personal data.  Subsequently, the personal data provided will be kept duly blocked for the legally stipulated period of prescription of the actions that may arise as a result of the relationship between TRIFERMED and the Data Subjects.  Once the maximum period has arrived, TRIFERMED will anonymize or delete the personal data.

3. Capture and use of the personal images of the attendees to the Trifermed Awards

For what purposes do we process your data?Which is the legal basis for the processing of your data?What personal data do we collect from you?How long will we keep your personal data?
Capture, use, reproduce and disseminate the image of the attendees by photography, audio and video means in order to promote, publicize and disseminate the event on the Website, corporate profiles on social networks and publications and articles in the press and digital media
Express consent that the attendees provide to TRIFERMED for the capture and use of his/her image during the celebration of the Trifermed Awards. ImageYour personal data will be processed by TRIFERMED if the attendee does not request the erasure or objection of his/her personal data.  Subsequently, the personal data provided will be kept duly blocked for limitation of the actions that may arise as a result of the relationship between TRIFERMED and the attendees.  Once the maximum period of data processing has arrived, TRIFERMED will anonymize or delete the personal data of the Data Subjects.

4. Management of personnel selection processes

For what purposes do we process your data?Which is the legal basis for the processing of your data?What personal data do we collect from you?How long will we keep your personal data?
Assesses the job application submitted by the user and, where appropriate, manage their CV and take it into account in future personnel selection processes. 
Candidate’s consentName and surname Date of birth Gender Personal address Telephone number and email address.  Image Personal information included in the CV such as professional experience, academic record, degrees, skills, competencies, recommendations, etc.Your personal data will be processed until the assignment of the job, for 2 years from the moment they were collected or provided by the candidate or until the latter exercise his suppression or opposition right or withdraws his consent.  Once the maximum period of data processing has arrived, TRIFERMED will anonymize or delete the personal data of the candidate.

5. Analysis of the use, operation and improvement of the Website 

For what purposes do we process your data?Which is the legal basis for the processing of your data?What personal data do we collect from you?How long will we keep your personal data?
Recognize the user when he/she returns to the Website. Maintenance of the safety and protection of the Website from malicious uses.  Adapt the Website to the device that it is being used.  Adapt the Website to the personalization criteria chosen by the user and remind them.  Study possible improvements of the Website in order to optimize the usability experience and implement them.  Show the contest of the Website correct and requested by the user at any time.  Enable the possibility to share corporate Website content in social media.

User’s consentInformation about your use and navigation of the Website (website from which you arrive on the Website, layers you have visited of the latter, processes initiated and abandoned, IP address, type of device from which you access, Internet browser used, time you have remained on the Website, etc.).We will retain your personal data for as long as each type of cookie needs or until you withdraw your consent or exercise your right of opposition.  Once the maximum period of data processing has arrived, TRIFERMED will anonymize or delete the user’s personal data.

6. Maintenance of updated deletion lists in order to avoid being contacted if the user requests so. 

For what purposes do we process your data?Which is the legal basis for the processing of your data?What personal data do we collect from you?How long will we keep your personal data?
Storage of your information in a deletion list, in case you have objected to a data processing or you have exercised the right of erasure.  Legal obligation: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and the free movement of such data and repealing Directive 95/46/EC, obliges us to respect your rights and maintain evidence of our compliance with your request for the exercise of the right to erasure.Name and surname EmailWe will retain the personal data for the legally provided period and, subsequently, during the limitation period for the filing of any claim in relation to our effective or poor response to the right of deletion or opposition that we have exercised.  Once the maximum period of data processing has arrived, TRIFERMED will anonymize or delete the user’s personal data.

6. WHO DO WE COMMUNICATE YOUR DATA TO?

TRIFERMED may communicate the personal data of the Data Subjects to third parties which their intervention is necessary for the correct performance, organization, and management of Trifermed Awards, and only when this communication is strictly necessary for reaching the purpose of the processing. 

If Data Subjects give their consent for the capture and use of their image during the celebration of the Trifermed Awards, personal image might be communicated to third parties, which are specially linked to the company.

Other possible third parties to which we may communicate your data, upon legal, judicial or administrative request and / or necessary compliance with a legal obligation that legitimizes the communication: 

  • Legal advisors 
  • Courts and Tribunals
  • Tax Administration
  • Governance agencies and Public Administrations
  • Security forces and bodies
  • Spanish Data Protection Agency 

We may also communicate your personal information in the following cases: 

  • If we or substantially all of our assets are acquired by a third party in which case, the personal data we hold from our partners and users will be one of the transferred assets. Any such operation will be reported and communicated.
  • To protect the security of the rights of our staff, our associates and users and our information systems and defend the interests of the company itself. This includes exchanging information with law entices or tribunals in cases of fraud detection, identity theft or any other use, treatment or unlawful act. 

7. WHO CAN ACCESS YOUR PERSONAL DATA?

TRIFERMED informs you that we work with third-party providers whose services are necessary for the correct presentation, usability and maintenance of the Website and our information systems and that, to render those services, they may need to have access to your personal data. This is the case, for example, of services providers who help us to improve and optimize our Website, technology service providers or suppliers or those who provide us with maintenance services for our databases and information systems. TRIFERMED signs the corresponding data processing agreements with all its data processors.

8. ARE YOUR PERSONAL DATA SAFE AND SECURE?

In order to ensure the fair and transparent processing of your personal information, we will adopt appropriate procedures that will include the implementation of technical and organizational measures that take into account the potential risk and correct any inaccuracies identified in the personal data processed, so that the risk of any error is minimized, processing your personal data fairly and securely. We do not transfer your personal data outside the European Economic Area. 

All information you provide to us is stored in secure servers. Thus, once we have received all your information, we will use strict security procedures to try to prevent any unauthorized access. Unfortunately, the transmission or communication of information over the Internet is not secure. 

Likewise, we ensure that our service providers also enjoy adequate security standards for the protection of personal data for which they have or may become accessed, in compliance with the applicable data protection legislation in force at all times.

9. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may vary over time due to possible changes in criteria followed at any time by the Spanish Data Protection Agency or other supervisory authorities, legislative changes that may take place and jurisprudence that apply to this Privacy Policy. TRIFERMED therefore reserves the right to modify this Privacy Policy in order to adapt it to these criteria, as well as to jurisprudence or legislative developments. 

Last version: September 2021