Privacy Policy

Privacy Policy

The purpose of this Privacy Policy is to inform you about how your personal data is processed when you browse or use the services included on our website, so that you can freely decide whether you wish to provide it for the purposes set out in this document.

Who is responsible for processing my personal data?

We inform you that the entity responsible for the personal data we request from you is: NABERAN SAREAK, S.L., with address at Mutrikuko Industrialdea, 15, 20830 Mutriku, Gipuzkoa (hereinafter Naberan).

If you wish to contact us, you can do so at:

• The following email address: naberan@naberan.com
• The following telephone number: 943 19 51 22

How was my personal data obtained?

The personal data that will be processed comes from:

• Completion of the fields collected in the forms published on the website.
• Cookies. For more information about this processing, please consult our cookie policy.

Legal basis for processing your personal data

The processing of personal data we carry out is based on the following legal bases:

Consent of the data subject (art. 6.1.a GDPR)

When the user provides us with their data through contact forms, newsletter subscriptions, account creation or acceptance of commercial communications.

Such consent is always free, informed and revocable at any time, without affecting the lawfulness of the processing carried out prior to its withdrawal.

Performance of a contract or application of pre-contractual measures (art. 6.1.b GDPR)

When the processing is necessary to manage the contractual relationship with the user: provision of services, order processing, invoicing, customer service, etc.

Also in cases where the user requests information prior to contracting.

Compliance with a legal obligation (art. 6.1.c GDPR)

When the processing is necessary to comply with obligations established in the applicable legislation, such as:

• Tax and accounting obligations.
• Response to requirements from public or judicial authorities.
• Retention of data to address possible legal liabilities.

Legitimate interest of the controller (art. 6.1.f GDPR)

When the processing is necessary for the satisfaction of legitimate interests, provided that the fundamental rights and freedoms of the user do not prevail over such interests. Examples:

• Improving the quality of our services and the browsing experience.
• Preventing fraud or improper use of the website.
• Conducting satisfaction surveys.

How should my data be processed?

The processing of your personal data will respect the following principles:

• Principle of lawfulness, fairness and transparency: we will request your consent for the processing of your personal data when legally required and we will inform you clearly and transparently about all aspects related to the processing of your personal data, your rights and how to exercise them.
• Principle of data minimisation: we will request only the data strictly necessary, adequate and proportionate in relation to the purpose for which it is collected.
• Principle of storage limitation: personal data will be processed for the time strictly necessary for the purpose for which it was collected. Once the legal liabilities arising from the processing have expired, the data is definitively deleted.
• Principle of integrity, availability and confidentiality: we apply technical and organisational security measures proportionate to the risk and the state of technology, to guarantee the integrity, availability and confidentiality of your personal data.

For what purpose will my personal data be processed?

Your personal data will be used for the following purposes:

• To respond to your request.
• If you contract any of our products or services, we will use your personal data for their management and invoicing.
• If you submit your CV, we understand that your intention is for us to keep it indefinitely in order to include you in present or future selection processes, without prejudice to your right of cancellation or objection, which you may exercise at any time free of charge.

How long will my personal data be retained?

The personal data provided will be retained only for the time strictly necessary to fulfil the purposes for which it was collected, and as long as the user does not request its deletion. Specifically:

• Data of clients and registered users: retained for the duration of the contractual relationship and, after its termination, for the period necessary to address possible legal liabilities (usually 6 years, in accordance with commercial and tax regulations).
• Contact data (forms, enquiries, customer service emails): kept only for the time necessary to respond to the request and for a maximum of 12 months for follow-up purposes.
• Data for commercial communications and newsletters: retained as long as the data subject does not withdraw their consent or request to unsubscribe. You may exercise your right to object or to erasure at any time.
• Data related to legal obligations: certain information must be retained for the time necessary to comply with tax, accounting or administrative obligations: normally 4 to 6 years, depending on the applicable regulations.
• Data of candidates in selection processes (if the website collects CVs): retained for a maximum period of 24 months unless the candidate requests its deletion beforehand.

What data must I provide?

All requested personal data marked with an asterisk are essential to acquire or contract our products and/or services. If you do not provide any of this mandatory data, we will not be able to assist you.

Will my personal data be communicated to third parties?

When necessary to respond to your request or to manage your relationship with Naberan, your personal data may be shared with the group companies listed below:

NABERAN ITSAS NET, S.L.
Illunzar 4-C P.I. Kareaga 48270 Markina (Bizkaia)
Tel.: +34 943 195122
naberan@naberan.com

NABERAN FRANCE S.A.R.L.
Avenue de la Republique Z.A. Poriguenor 29730 Le Guilvinec (France)
Tel.: +33 298 582739
david@naberan.com

NGOM & FRERES
2 Avenue Ballay X Rue de l'Administration 17100 Dakar (Senegal)
Tel.: +22 1338424020
ngfdepcom@gmail.com

Your rights

• You have the right to access your personal data.
• You have the right to request its rectification or deletion.
• You may withdraw the consent given at any time.
• You may request the restriction of the processing of your personal data.
• You have the right to object to the processing of your personal data.
• You have the right to the portability of your personal data.

To exercise any of these rights, you must submit a request to the address of the data controller set out in the first point of this privacy policy. Please remember that the request must be submitted by the data subject themselves. If you wish to obtain more information about your rights or how to exercise them, you may contact the Spanish Data Protection Agency – www.agpd.es.

Cookies

We use only technical session cookies necessary for the correct functioning of the website. We do not create user profiles nor do we share data with third parties.

If you would like more information about cookies, you can consult it at the following link: Cookie Policy.

Data quality

The User guarantees that the Personal Data provided to Naberan is truthful and is responsible for communicating any change to it. The User shall be solely responsible for any direct or indirect damage or loss that may be caused to Naberan or to any third party as a result of completing the forms with false, inaccurate, incomplete or outdated data. The User must not include personal data of third parties without their prior informed consent as established in this privacy policy, being solely responsible for its introduction.

Confidentiality

Your personal data is classified as confidential information; therefore, all processing of this data will be carried out guaranteeing the utmost secrecy from third parties and applying the necessary security measures to ensure its security.

Security measures

Naberan has adopted the necessary measures to prevent the alteration, loss, processing or unauthorised access to personal data, taking into account at all times the state of technology, the nature of the stored data and the risks to which they are exposed, whether arising from human action or from the physical or natural environment; however, the User must be aware that security measures on the Internet are not impregnable.

Particular conditions

Certain services provided by Naberan may contain particular conditions with specific provisions regarding the protection of personal data. In all matters not regulated by the particular conditions, this privacy policy shall apply on a supplementary basis.