Privacy Policy

1. INTRODUCTION

This privacy policy (hereinafter, “Privacy Policy”) regulates the processing of your personal data as a user of the website www.adkomo.com (hereinafter, the “Website”), owned by ADKOMO LIMITED (hereinafter, “ADKOMO”).

Likewise, the purpose of this Privacy Policy is to provide information about the rights that assist you under Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons. regarding the processing of personal data and the free circulation of these data and which repeals Directive 95/46/EC (hereinafter, “GDPR”) and Organic Law 3/2018, on the Protection of Personal Data and guarantee of digital rights (hereinafter, “LOPDGDD”).

All capitalized terms in this Privacy Policy shall have the meaning set forth in the terms of use unless they are expressly defined in this Privacy Policy.

2. RESPONSIBLE FOR THE TREATMENT

ADKOMO LIMITED, with registered office at 78 Bonham Strand, Workington Tower, Floor 25, Sheung Wan, Hong Kong, and registered in the Hong Kong Companies Registry under number 2676735, with a permanent establishment in Spain with address at Carrer de Bailen, 71 Bis, 6-1, 08009 Barcelona, ​​Spain, and NIF W7202118A, is the entity responsible for the processing of your personal data.

For any query, request, or clarification regarding the processing of your personal data, you can contact our Data Protection Officer at the following email address: dp*@ad****.com

3. PERSONAL DATA PROCESSED

ADKOMO will process the following categories of personal data, for the purposes detailed below:

  • Identification and contact information: name and surname, email and telephone.
  • Employment Details Data: corporate contact details.
  • Academic and professional data: in those cases in which you send us your CV spontaneously or the User is interested in any of the job offers or internships published on the Website, data related to training/qualifications, academic history, professional experience, belonging to professional colleges or associations.
  • Navigation data: IP address, browser type and User behavior on the Website. For more information, see our Cookies policy.
  • Other additional data provided by the User in the communications that he maintains through the channels enabled for this purpose, or within the framework of the selection processes in which the User may be included.

The personal data processed is provided directly by the User when accessing, browsing, and using the Website, or when contacting ADKOMO through the forms provided for this purpose on the Website or through the communication channels detailed in each of the sections. of the Website.

The User guarantees that the data provided is true, exact, and complete and undertakes to keep them duly updated, in such a way that they respond to their real situation.

In the event that the User provides personal data of third parties, the User guarantees that they have been informed of the points contained in this Privacy Policy, exempting ADKOMO from any responsibility in this regard.

4. PURPOSE OF THE TREATMENT

ADKOMO will process the data provided by the User for the following purposes:

  • Manage and respond to contact requests made by the User through the forms on the Website, corporate email addresses, or other forms of contact indicated.
  • Maintain commercial, contractual, or collaborative relationships with the User or with the company, entity, or organization in which the User provides their services.
  • Manage the process of selection and hiring of personnel or interns, in order to assess the application for employment or internships of the User who has sent their CV or has registered in any offer published on the Website, through the means indicated for this purpose.
  • Carry out anonymous statistical reports regarding the access habits, preferences, and behavior of the User on the Website.
  • Comply with legally established obligations, as well as verify compliance with contractual obligations, including fraud prevention.

5. LEGITIMATION OF TREATMENT

ADKOMO will treat the User’s personal data in accordance with the following legitimizing bases:

  • Manage and respond to contact requests made by the User: the legal basis for the processing of data derived from this purpose is the User’s consent, which may be withdrawn at any time. In the event that the User withdraws consent, the query or question raised cannot be processed.
  • Maintain commercial, contractual, or collaborative relationships with the User or with the company, entity, or organization in which the User provides their services: the processing of personal data responds to the need to be able to comply with our contractual obligations towards the User, and in case of having obtained your data for the purpose of relating to the company, entity or organization in which the User provides his services, the processing of his corporate contact data responds to a legitimate interest of ADKOMO, expressly recognized by the regulations about privacy
  • Manage the process of selection and hiring of personnel or interns: if the application is spontaneous, the User’s data will be processed based on consent, and if it applies to a specific offer based on the application of pre-contractual measures at the request of the interested party.
  • Carry out anonymous statistical reports regarding the access habits, preferences, and behavior of the User on the Website: all the treatments derived from this purpose will have a legitimate interest as the basis of legitimation, expressly recognized by the data protection regulations. This legitimate interest is based on being able to offer ADKOMO services to the User with the highest quality and best possible experience.
  • Comply with legally established obligations: all processing derived from this purpose will be based on compliance with a legal obligation.

6. DATA RECIPIENTS

ADKOMO may transfer your data to the recipients indicated below:

  • Public Administrations, Courts, and Tribunals, as well as State Security Forces and Corps, in the cases provided by law, based on compliance with a legal obligation.
  • Banks and financial entities for the collection of services that are provided by ADKOMO to its customers.
  • Service providers that have to access your personal data for the provision of the services contracted by ADKOMO, and with which ADKOMO has signed the confidentiality and personal data processing contracts necessary and required by the regulations to protect your privacy.

In those cases in which ADKOMO has contracted the services of technology providers located outside the European Union, these international transfers are regularized by adopting all the guarantees that are applicable in accordance with European regulations to guarantee an adequate level of protection, in particular by signing the standard contractual clauses adopted by the European Commission for international transfers of personal data.

For more information about the recipients of your data and the guarantees applied to international transfers to preserve your privacy, you can contact our Data Protection Officer at the following email address: dp*@ad****.com

7. CONSERVATION PERIOD

The User’s personal data will be kept by ADKOMO for the following periods:

  • Manage and respond to contact requests made by the user: the data will be kept for the period necessary to process and reply to your request and, once completed, will keep them blocked during the prescription period of the actions legal deriving from said request.
  • Maintain commercial, contractual, or collaborative relationships with the User or with the company, entity, or organization in which the User provides their services: the data will be kept as long as the relationship with ADKOMO is maintained and, after the termination of the said relationship for any reason, during the applicable legal prescription periods. In this case, they will be processed for the sole purpose of proving compliance with our legal, tax, or contractual obligations.
  • Manage the process of selection and hiring of personnel or interns: the data will be kept for a maximum period of two years, with attention to possible future selection processes.
  • Carry out anonymous statistical reports regarding the access habits, preferences, and behavior of the User on the Website: the information will be used in aggregate form for the preparation of reports, statistics, and analysis, during the period necessary to process and prepare the aforementioned reports. , statistics and/or analysis, and, once it is finished, it will keep them blocked, during the limitation period of the legal actions derived from the aforementioned request.
  • Comply with the legally established obligations: the data provided to comply with the obligations derived from the services offered by ADKOMO will be kept for the legally established periods.

8. AUTOMATED DECISIONS

ADKOMO does not make decisions that may affect you based solely on the automated processing of your personal data. All decision-making processes related to the treatment purposes described above are carried out with human intervention.

9.EXERCISE OF YOUR RIGHTS

We inform you that you have the right to exercise the following rights:

  • Right of access to your personal data to know which ADKOMO is processing and the processing operations carried out with them.
  • Right of rectification of your personal data that is inaccurate.
  • Right of opposition to the processing of your personal data when said processing is based on legitimate interest. ADKOMO will stop processing the data, except for compelling legitimate reasons, or the exercise or defense of possible claims.
  • Right of suppression of your personal data in the cases provided for by law (for example, when they have been processed unlawfully or are no longer necessary in relation to the purposes for which they were collected).
  • Right to limitation of the processing of your personal data when the accuracy, legality, or necessity of such processing is doubtful, in which case we may keep them for the formulation, exercise, or defense of claims.
  • Right to portability of your personal data, so that you receive them in a structured, commonly used, machine-readable, and interoperable format, and can transmit them to another controller, provided that the processing is based on consent or on the performance of a contract.
  • Right to not be subject to an automated decision based solely on the processing of your data, including profiling, which produces legal effects on the User or significantly affects him in a similar way.
  • Right to revoke your consent whenever.

You can exercise at any time and for free by sending a communication to the email address dp*@ad****.com, indicating the right you wish to exercise, and attached a copy of your national identity document or equivalent document.

Likewise, if you consider that the processing of your personal data carried out by ADKOMO violates your rights or the data protection regulations, we inform you that you can file a claim with the Spanish Agency for Data Protection.

10. SECURITY MEASURES

ADKOMO undertakes to adopt the necessary technical and organizational measures, according to the state of the art at the time of writing this Privacy Policy, to protect your personal data.

This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.

Please note that if commercially reasonable technical precautions are not taken to protect your data, ADKOMO cannot guarantee that data transmission over the Internet is 100% secure. Any transmission of data through the Website is at your own risk.

11. MODIFICATIONS

ADKOMO reserves the right to modify this Privacy Policy, at any time, to guarantee proper compliance with current regulations on data protection. The access and use of the Website after the entry into force of said modifications imply acceptance of these.

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