Data protection
The necessary security measures will be adopted to guarantee the security of the data, as determined by the risk analysis carried out in accordance with Article 32 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter, GDPR).
Likewise, the record of processing activities provided for in Article 30 of the GDPR will be kept in relation to this type of processing from the moment such procedures are set up.
Persons who make a communication through the ethics channel declare and guarantee that the personal data provided is true, accurate, complete and up to date, and will hold VENAIR harmless from any liability that may arise from a breach of those declarations and guarantees. In all cases, data relating to any fact investigated will be retained.
The personal data provided in the context of communications and queries made to the ethics channel, as well as any updates to that data, will be processed by VENAIR, with registered office at Carrer de la Cerdanya, 26, 08226, Terrassa, Barcelona, Spain.
The purpose of this processing is the investigation and resolution of inappropriate actions or conduct, particularly in criminal and regulatory compliance matters. Its purpose is also the management of queries, questions and/or proposals for improvement of the existing systems at VENAIR.
VENAIR will retain personal data for the time strictly necessary to resolve communications of non-compliance and to deal with the corresponding queries and, once these have been resolved, the data will be kept duly blocked in order to comply with the legal obligations applicable in each case.
The legal basis for the processing of data is compliance with the legal obligation to resolve the queries raised, applicable by virtue of the provisions of Organic Law 10/1995 of 23 November on the Criminal Code.
No automated decisions that may affect you will be taken on the basis of the personal information provided.
The rights of access, rectification, erasure, objection and restriction of processing, the right to object to processing in the cases permitted by law, and the right to data portability may be exercised before VENAIR, under the terms specified by the regulations in force, by written communication (by email —dataprotection@venair.com— or by post —Carrer de la Cerdanya, 26, 08226, Terrassa, Barcelona, Spain—, quoting the reference “Data Protection”), attaching a photocopy of your national identity document and stating the specific right you wish to exercise. You also have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos).
This personal data will only be disclosed to third parties to whom VENAIR is legally or contractually obliged to provide it, and to those companies in the legal sector and in its group of companies to which, where applicable, it has entrusted the provision of consultancy and advisory services in relation to the management of the ethics channel on behalf of VENAIR, to the extent necessary for the provision of those services. Under no circumstances will VENAIR carry out international transfers of your personal data to third countries or to an international organisation. Only if the fact brought to VENAIR's attention gives rise to administrative or judicial proceedings may the data provided be disclosed to the competent authorities for investigation and sanction. Where applicable, the contracts provided for in Article 28(3) of the GDPR will be signed with external providers who have access to or process personal data and, where applicable, transfers to third countries outside the European Union will be regularised in accordance with the regime provided for in Articles 44 et seq. of the GDPR.