Legal notice and Terms of Use
WARNING: THE ENGLISH VERSION OF THE TERMS AND CONDITIONS IS FOR PURELY INFORMATIONAL PURPOSE. SHOULD ANY CONTRADICTION ARISE BETWEEN THE ENGLISH VERSION AND THE SPANISH VERSION, THE LATTER SHALL ALWAYS PREVAIL.
This Legal Notice regulates the use of the website www.clikalia.com (hereinafter, the Site) which informs about goods or services offered by Clikalia companies, which can be consulted in the Legal Notice of the Clikalia website [INSERT LINK] (hereinafter, Clikalia).
Clikalia is the owner of all rights to the Website. The simple access, surfing and use of the Website attributes the condition of user of the same (hereinafter, the "User") and implies the acceptance of this clause of Legal Notice and Conditions of Use. The information available through this website is not subject to contract and may be modified without prior notice.
Clikalia will guarantee confidentiality and anonymity (if the user so chooses), with respect to the personal data of the whistleblower.
Privacy Policy and data processing
HELAS assumes the status of data processor in relation to personal data that may be provided in complaints or queries to companies that have contracted the service with Clikalia, provided that the user does not choose anonymity.
In the processing of personal data, HELAS undertakes to guarantee and protect public freedoms and fundamental rights of individuals and, especially, their honor and their family and personal privacy, obliging in this regard to carry out the corresponding data processing in accordance with current regulations at all times and to keep the most absolute secrecy in relation to the information that may be provided through the channel.
The data controller of the data sent through the channel of complaints or queries will be the company that has contracted the service, in this case, Clikalia. You can get more information about data processing in the Privacy Policy.
Intellectual and Industrial Property
Clikalia reserves all rights over trademarks, trade names or other distinctive signs, patents, and intellectual property, with respect to the content and design of the Web except for those reserved to the licensor or assignee of the use of the channel. All the contents of the Web, including without limitation, texts, graphics, images, its design, and the intellectual property rights that may correspond to said contents, as well as trademarks, trade names or any other distinctive sign are the property of Clikalia, except those reserved to the licensor or assignee of the use of the channel.
Terms of use for the user
Law and jurisdiction
This Legal Notice and Conditions of Use is subject by Spanish law. In case of dispute or controversy related to the application or interpretation of the clauses contained in the Legal Notice, the Parties will submit to the Courts and Tribunals that are territorially competent according to current legislation. Date of last update: 15 February 2023.
Privacy Policy
The ethical channel is managed by Clipiso Desarrollo S.LU., an entity that acts as a service provider, in charge of processing, for the comprehensive management of the Entities that make up the CLIKALIA GROUP (hereinafter, Clikalia). These Entities can be consulted in Point 1 of the Legal Notice on the Clikalia website [ENTER LINK].
The use of the services, you can receive information addressed to any of the Entities of the GROUP, which in this case will act as the company responsible for the processing of the data.
Remember that this channel is not intended to communicate emergencies.
The ethical channel is managed by Clipiso Desarrollo S.LU. (hereinafter, Clikalia), using the HELAS platform, owned by Digital Productos Development, S.L., a company specialized in offering ethical channel management systems. Clikalia maintains a contractual relationship with HELAS as data processor for the purpose of receiving, storing and sending communications to the Compliance department of Clikalia.
HELAS guarantees security and confidentiality for the purpose of the contracted processing.
Below, we show you the basic information about how we treat your personal data:
Information Protection of personal data | |
Data Controller | The companies of the CLIKALIA Group identified in Point 1 of the Legal Notice. |
Data category
| · Name and surname, telephone, and e-mail (if the whistleblowing is not anonymous). · Facts related to the complaints and other information provided by the informant such as name and surname of the complainant and witnesses, personal characteristics, employment details, signature, etc. · Infractions and administrative sanctions. · No data of special categories will be processed, except that can be provided by the informant. |
Purpose of the Process | Reception and management of communications and queries received through the ethical channel, as well as the instruction and investigation of files related to infractions for the detection of crimes and prevention of criminal responsibilities, avoid conduct contrary to internal regulations, as well as any other that is applicable. |
Legitimation | · The process is based on the public interest in accordance with the article 6.1.e) RGPD in relation to The LOPDgdd. · Legitimate interest of the company to conduct the necessary checks to detect and prevent breaches or breaches of our internal regulations (art. 6.1 f RGPD). |
Data retention | Personal data will be kept in accordance with the provisions of law. Specifically, the data will be kept for the time necessary to decide on the appropriateness of initiating an investigation into the facts communicated, which may last for a maximum of three (3) months from since the date of registration of the communication/complaint. In any case, after this time, all that data must be deleted from the system, unless the purpose of conservation is to leave evidence of the operation of the channel, in which case they will be anonymized. However, in case it is necessary to process the personal data for a longer time to continue the investigation or because it is decided to take legal action, the data will be kept, in an environment other than the ethical channel, as long as it is necessary to conclude the investigation or for the exercise of actions by Clikalia in the corresponding legal proceedings. Communications/complaints that have not been acted upon will only be recorded in the system in anonymized form but will not be blocked. |
Recipients | Likewise, ethical channel data will be communicated to external professional cloud hosting service providers and ethical channel management providers who will process the data as Data Processors and, when necessary, to HR personnel for the adoption of possible sanctions or disciplinary measures. The facts that may constitute a criminal or administrative offence, including personal data, may be communicated to the Security Forces and Corps, the Public Prosecutor's Office, the Judiciary or other public administrations with competence in relation to the type of communication submitted. |
International data transfers | No international transfers will be made for the purpose of this processing, except to competent authorities outside the national territory on the basis of public interest or the fulfillment of legal obligations for the formulation, exercise or defense of claims. |
Rights | The interested party may exercise their rights of access, rectification, deletion and portability data, limitation, and opposition, as well as not being subject to decisions based solely on the automated processing of their data, when appropriate, at the addresses identified above. Likewise, we inform you that you can make a claim before the Spanish Agency for Data Protection, in case you consider that the processing of your data is not adequate ( www.aepd.es ) |
Date of last update: 15 February 2023.