PERSONAL DATA PROTECTION POLICY
CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L. is an organization that collects personal data through various means, which gives it a significant responsibility in designing and organizing procedures to ensure compliance with data protection laws. Therefore, CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L. will adopt all necessary security measures to guarantee the protection of the data collected.
In fulfilling these responsibilities, and in order to establish the general principles governing the processing of personal data within the organization, CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L.
approves this Personal Data Protection Policy, which it notifies and makes available to all its stakeholders, while also adhering to the following regulations:
- Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and the free circulation of these data (GDPR).
- Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
- Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).
I. SCOPE OF APPLICATION
This Personal Data Protection Policy applies to CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L., its administrative and management bodies, and staff, as well as all individuals who interact with the Organization, including service providers with access to data (“Data Processors”).
The data controller for the personal data collected by the Organization is: CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L., with Tax Identification Number (NIF): B25576299, whose representative is: JOSEP MARIA JAIME VITORES BAGUE (hereinafter, the Data Controller). Their contact details are as follows:
Address: CARRETERA L800 KM 13.01, ALCARRAS, LLEIDA, 25180
Contact phone numbers: 973296617, 615500355
Contact email: secretaria@circuitalcarras.cat
II. INFORMATION ON THE CONTROLLER AND PROCESSING OF PERSONAL DATA AT CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L.
Additional information on data processing is a set of more specific and expanded details that entities must provide to data subjects about how their personal data is managed. This concept stems from the transparency principle of the General Data Protection Regulation (GDPR) and complements the basic information initially provided, offering a greater level of detail on the processing activities.
Below, CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L. provides additional information on the data processing it carries out:
| Additional information on data protection |
| DATA ABOUT THE DATA CONTROLLER |
| Identity | CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L. |
| Address | L800 Highway, Km 13.01, Alcarràs, Lleida, 25180 |
| Contact phone numbers | 973296617, 615500355 |
| Email address | secretaria@circuitalcarras.cat |
| PURPOSES OF PROCESSING PERSONAL DATA |
| Data processing | Purpose of processing | Retention period |
| WEB FORM | CUSTOMER, ACCOUNTING, TAX, AND ADMINISTRATIVE MANAGEMENT | – Customer Management: 5 years. – Accounting: 6 years. – Tax: 4 years. – Administrative: 5 years. |
| VIDEO SURVEILLANCE | VIDEO SURVEILLANCE | VIDEO SURVEILLANCE: Maximum 1 month from the date of recording. |
| CLIENT ORGANIZERS | CUSTOMER, ACCOUNTING, TAX, AND ADMINISTRATIVE MANAGEMENT | Customer management: for the duration of the relationship and subsequently for the statutory limitation periods (with blocking). Accounting: 6 years. Tax: 4 years. Administrative: for the duration of the management and subsequently for the statutory limitation periods (with blocking). |
| SUPPLIERS / INVOICING | CUSTOMER MANAGEMENT, ACCOUNTING, TAX, AND ADMINISTRATIVE | Customer management: for the duration of the contractual relationship and, once terminated, for the statutory limitation periods for legal actions. Accounting: 6 years. Tax: 4 years. Administrative: for the time necessary for the purpose and, thereafter, blocked for the statutory limitation periods for liabilities. |
| HUMAN RESOURCES | CUSTOMER MANAGEMENT, ACCOUNTING, TAX AND ADMINISTRATION, PAYROLL MANAGEMENT, HUMAN RESOURCES | CUSTOMER MANAGEMENT, ACCOUNTING, TAX AND ADMINISTRATION: 6 years (commercial documentation) and 4 years (tax documentation) PAYROLL MANAGEMENT: 4 years HUMAN RESOURCES: 4 years (documentation/supporting documents that prove compliance in affiliation, registrations/terminations/changes, contributions and salary receipts). |
| PILOT CLIENTS | CUSTOMER, ACCOUNTING, TAX, AND ADMINISTRATIVE MANAGEMENT | CUSTOMER MANAGEMENT: During the term of the contractual relationship and, after its termination, for the limitation periods of any potential legal actions. ACCOUNTING: 6 years from the last related entry/record. TAX: 4 years from the end of the deadline for filing the corresponding tax return. ADMINISTRATIVE: During the term of the management and, after its termination, for the limitation periods of any potential administrative or legal actions. |
| CURRICULUM VITAE | CUSTOMER SERVICE, ACCOUNTING, TAX AND ADMINISTRATION, HUMAN RESOURCES | Customer Service: 5 years Accounting, Tax and Administration: 6 years (Accounting) / 4 years (Tax) Human Resources: 4 years (Employee Documentation) / 5 years (Occupational Risk Prevention) / 10 years (Occupational Health Records) |
| LEGITIMACIES FOR THE PROCESSING OF PERSONAL DATA |
| Data processing | Legal basis |
| WEB FORM | Express consent of the interested party |
| VIDEO SURVEILLANCE | Legitimate interest in video surveillance |
| ORGANIZING CLIENTS | Execution of a service provision contract |
| SUPPLIERS/BILLING | Execution of a sales contract |
| HUMAN RESOURCES | Legal obligation under labor legislation |
| PILOT CLIENTS | Execution of a service provision contract |
| CURRICULUM | Express consent of the interested party |
| RECIPIENTS OF YOUR PERSONAL DATA |
| Data processing | Provision of data transfers | No |
| WEB FORM | INSURANCE COMPANIES | No |
| VIDEO SURVEILLANCE | PUBLIC ADMINISTRATION WITH COMPETENCE IN THE MATTER | No |
| ORGANIZING CLIENTS | No transfers are anticipated | No |
| SUPPLIERS/BILLING | PUBLIC ADMINISTRATION WITH COMPETENCE IN THE MATTER | No |
| HUMAN RESOURCES | PUBLIC ADMINISTRATION WITH COMPETENCE IN THE MATTER | No |
| PILOT CLIENTS | INSURANCE COMPANIES | No |
| CURRICULUM | No transfers are anticipated | No |
| RIGHTS THAT BELONG TO THEM AND MEANS AT THEIR DISPOSAL |
| Anyone has the right to obtain confirmation as to whether CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L. is processing personal data concerning them. Interested parties have the right to access their personal data, as well as to request the rectification of inaccurate data, or where appropriate, to request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected. In certain circumstances, interested parties may request the limitation of the processing of their data, in which case we will only keep them for the exercise or defense of claims, as well as to comply with the legally established retention periods. Furthermore, interested parties may object to the processing of their personal data. Therefore, CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L. will cease processing their data, except for legitimate and compelling reasons, or in the exercise of potential claims. Similarly, when certain circumstances exist and it is technically possible, interested parties will have the right to have their personal data transmitted directly to another controller or processor, upon request. To exercise the aforementioned rights, you must contact us by sending a written request to: ● CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L. CARRRETERA L800 KM 13.01, ALCARRAS, LLEIDA, 25180, or by email to secretaria@circuitalcarras.cat. We recommend including a copy of your ID with your request. |
III. PRINCIPLES APPLICABLE TO THE PROCESSING OF PERSONAL DATA
The Personal Data Protection Policy is a proactive Responsibility measure, which aims to ensure compliance with applicable legislation in this area and, in relation to this, respect for the right to honor and privacy in the processing of personal data of all persons related to CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L.
In accordance with the provisions of this Policy, the Principles governing data processing within the organization are established, and consequently, the procedures and organizational and security measures that the individuals affected by this Policy undertake to implement within their area of responsibility.
In relation to the above, CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L. will ensure compliance with the following principles:
- Legality, loyalty, transparency and purpose limitation.
Data processing must always be communicated to the affected person, through established clauses and procedures; and will only be considered legitimate if there is consent for the data processing (with special attention to that given by minors), or has another valid legitimation, and the purpose of the same is in accordance with the applicable regulations.
- Data minimization.
The data processed must be adequate, relevant and limited to what is necessary in relation to the different purposes of the processing.
- Accuracy
The data must be accurate and, if necessary, kept up to date. In this regard, the necessary measures will be taken to ensure that personal data that is inaccurate with regard to the purposes of the processing is deleted or rectified without delay.
- Limitation of the storage period.
The data will be kept in a form that permits identification of the data subjects for no longer than is necessary for the purpose of the processing in question.
- Integrity and Confidentiality.
Personal data will be processed in a manner that ensures adequate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, by implementing appropriate technical and organizational measures.
- Data transfers.
The purchase or acquisition of personal data is prohibited, provided it originates from legitimate sources, or in cases where such data has been collected or transferred in violation of the law or its legitimate origin is not sufficiently guaranteed.
- Contracting suppliers with access to data.
Only suppliers offering sufficient guarantees to implement appropriate technical and security measures for data processing will be selected for contracting. A formal contract will be drawn up with these suppliers to this effect.
- International data transfers.
All processing of personal data subject to European Union regulations that involves a transfer of data outside the European Economic Area must be carried out in strict compliance with the requirements established in the applicable law.
- Rights of affected persons.
The Organization will facilitate the exercise of the rights of access, rectification, erasure, limitation of processing, objection and portability for the affected persons, establishing for this purpose the internal procedures, and in particular, the models that are necessary and appropriate for their exercise, which must satisfy, at least, the legal requirements applicable in each case.
CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L. will promote that the principles set out in this personal data protection policy are taken into account:
- In the design and implementation of all work procedures
- In the products and services offered
- In all contracts and obligations that they formalize or assume and
- In the implementation of any systems and platforms that allow access to your plan by employees or third parties and/or the collection or processing of personal data.
IV. PERSONAL DATA OF MINORS
In accordance with Articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights, only those over 14 years of age may give their consent for the lawful processing of their personal data by CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L. If the data subject is under 14 years of age, the consent of their parents or guardians will be required for processing, and such processing will only be considered lawful to the extent that they have authorized it.
V. PRIVACY AND SECURITY OF PERSONAL DATA
CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L. undertakes to inform the user, without undue delay, when a personal data breach occurs that is likely to pose a high risk to their rights and freedoms. Following the provisions of Article 4 of the GDPR, a personal data breach is understood to be any breach of security that causes the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication of or access to said data.
Personal data will be treated as confidential by the Data Controller, who undertakes to inform and guarantee through a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom the information is made accessible.
VI. COMMITMENT OF THE STAFF OF CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L.
Therefore, we state that the employees of CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L. are informed of this Policy, and declare themselves aware that personal information is an asset of CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L., and in this respect they adhere to it, committing to the following:
- Carry out awareness training on data protection that CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L. makes available to you.
- Apply the user-level security measures applicable to your job, without prejudice to the responsibilities in their design and implementation that may be attributed to you based on your role within CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L.
- Use the established formats for exercising rights by affected users, and inform CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L. immediately, so that a response can be provided.
- Inform CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L., as soon as you become aware, of any deviations from what is established in this Policy, in particular “Personal data security breaches”, using the format established for this purpose.
VII. CONTROL AND EVALUATION
CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L. will carry out an annual verification, evaluation and assessment, as well as whenever there are significant changes in data processing, of the effectiveness of the technical and organizational measures to guarantee the security of the processing.
CIRCUIT DE VELOCITAT D’ALCARRAS VITORES S.L.