1. IDENTIFICATION

• Identity: ECOEMBES ENTIDAD ADMINISTRADORA, S.L.U. (hereinafter, “ECOEMBES”).
• NIF: B56540040.
• Registered office: Cardenal Marcelo Spínola 14 / 2nd Floor. 28016 Madrid.
• Contact information for the Data Protection Officer: oficiadeprivacidad@ecoembes.com.

2. GENERAL INFORMATION

By accepting this Privacy Policy, the user is informed that the personal data provided through the website located at the URL https://packagingchallenge.thecircularlab.com/ (hereinafter, the “Website” ) are processed by ECOEMBES, as well as the data derived from your browsing and any other data that you may provide to ECOEMBES in the future.

The user must carefully read this Privacy Policy, which has been written in a clear and simple manner, to facilitate its understanding, freely and voluntarily determining whether they wish to provide their personal data to ECOEMBES.

3. OBLIGATORY TO PROVIDE THE DATA

The data requested in the forms on the Website are, in general, mandatory (unless otherwise specified in the required field) to fulfill the established purposes.

Therefore, if they are not provided or are not provided correctly, they will not be able to be addressed, without prejudice to the fact that you will be able to freely view the content of the Website.

4. FOR WHAT PURPOSE WILL THE USER’S PERSONAL DATA BE PROCESSED?

The personal data provided through the Website or other means made available to users will be processed by ECOEMBES in accordance with the following purposes:

1. Adequate attention and management of requests made through the enabled forms: the personal data collected by ECOEMBES will be processed, both automated and, where appropriate, conventional to be able to contact the user in order to attend to and manage appropriately the requests made through the forms enabled for this purpose.

2. Remission, by electronic means, of information related to the activities related to the Circular Packaging Challenge program: the data provided will be processed with the purpose of sending the user commercial communications with information that may be of interest to them on issues related to Circular Packaging Challenge, as well as any recycling activity or initiative and other relevant information.

3. Manage your registration in the Circular Packaging Challenge program: the personal data collected by ECOEMBES will be processed in order to manage your registration in the Circular Packaging Challenge program. ECOEMBES may contact the user to inform them of the status of the project.

4. Sending satisfaction surveys: the data provided for this purpose will be processed by ECOEMBES to know the degree of satisfaction in relation to the provision of our services, projects and initiatives by the user.

5. Data provided for the exercise of rights: the data provided for the exercise of rights will be processed to meet your requests regarding data protection.

6. Data derived from the use of the Website: the data provided through the use of the Website will be processed for the purpose of carrying out the maintenance, support and updating of the Website, as well as for the resolution of possible technical incidents or any other other nature that may arise in relation to it. Likewise, they may be used to measure performance and perform analytics on access habits and activity carried out by users on the Website.

Likewise, navigation through the Website by the user may be managed and analysed using cookies. The user can obtain more information about this in our Cookies Policy.

5. WHAT USER DATA WILL ECOEMBES PROCESS?

ECOEMBES will process the following categories of user data:

1. Adequate attention and management of requests made through the enabled forms: identifying data (name and surname); contact information (email, telephone, postal code); any other data that the user provides in their query or request.

2. Submission, by electronic means, of information related to activities related to the Circular Packaging Challenge program: identifying data (name and surname); contact information (email, telephone).

3. Manage your registration in the Circular Packaging Challenge program: identifying data (name and surname, social networks); contact details (email).

4. Sending satisfaction surveys: identifying data (name and surname); contact information (email, telephone, address); transaction and service data (campaigns in which you have participated, activity with ECOEMBES).

5. Data provided for the exercise of rights: identification data (name and surname, ID); contact information (address, telephone, email address); as well as all the data that the user includes in the request.

6. Data provided through the use of the Website: location data through IP’s, such as browser or device, data derived from cookies, clicks, interactions, etc.

In the event that the user provides data from third parties, they declare that they have their consent and undertake to transfer the information contained in the Privacy Policy, exempting ECOEMBES from any responsibility in this regard. However, ECOEMBES may carry out periodic verifications to verify this fact, adopting the corresponding due diligence measures, in accordance with data protection regulations.

6. WHAT IS THE LEGITIMATION OF THE PROCESSING OF USER DATA?

The legitimacy of the processing of your personal data will be the following:

1. Adequate attention and management of requests made through the enabled forms: the basis for legitimizing the processing of data for this purpose will be the legitimate interest of ECOEMBES, consisting of correctly addressing the requests made by users, offering a satisfactory experience. of customer service. You may object to the processing of your data for this purpose at any time through the contact address of the Privacy Office.

2. Remission, by electronic means, of information related to activities related to the Circular Packaging Challenge program: the basis for legitimizing the processing of data for this purpose will be, on the one hand, legitimate interest, in the event that the user is a client. or associate of ECOEMBES, to send you information related or similar to the product or service originally contracted, by virtue of the legal authorization conferred in article 21.2 of Law 34/2002, of July 11, on information society services and of electronic commerce, and/or, on the other hand, consent, in the event that the user is not a client or associate of ECOEMBES or the commercial information sent is of a general nature.

You may object to the processing of your data for this purpose at any time through the contact address of the Privacy Office or through the link included in any commercial communication sent.

3. Manage your registration in the Circular Packaging Challenge program: the basis for legitimising data processing for this purpose will be the execution of the contractual relationship originated between the user and ECOEMBES.

4. Sending satisfaction surveys: the basis for legitimising data processing for this purpose will be the legitimate interest of ECOEMBES, consisting of knowing the degree of satisfaction of its users with its services and being able to constantly improve their experience based on the responses. You may object to the processing of your data for this purpose at any time through the contact address of the Privacy Office.

5. Data provided for the exercise of rights: the basis for legitimising the processing of said data is the legal obligation of ECOEMBES to manage such rights in accordance with the applicable regulations.

6. Data derived from the use of the Website: the basis for legitimising the processing of said data in order to maintain the security of the Website and carry out its maintenance is the legitimate interest of ECOEMBES in the correct functioning of the Website. In this regard, specific user data will not be processed, but rather the information is used in an aggregate manner to avoid interference with the rights and freedoms of users. Likewise, ECOEMBES has implemented technical security measures aimed at guaranteeing the privacy and confidentiality of the information processed. If you wish to obtain more information about this treatment, you can obtain it by requesting it at the email address officiadeprivacidad@ecoembes.com.

On the other hand, the basis for legitimising the processing of said data for the purpose of measuring performance and analytics will be the user’s consent, which may be revoked at any time and free of charge, without affecting the legality of the treatments. carried out previously.

The consents obtained for the aforementioned purposes are independent, so the user may revoke only one of them, not affecting the others or the legality of the treatments carried out previously.

To revoke said consent, the user may contact ECOEMBES through the following channels:

– Email: oficinadeprivacidad@ecoembes.com.

In the event that the interested party does not provide the aforementioned data or it is erroneous or inaccurate, we will not be able to respond to the request, making it impossible to provide the requested information or carry out the contracting of the services. Therefore, the person responsible for the treatment, ECOEMBES, will be exonerated from any responsibility that may arise from the non-execution of the professional assignment or from the consequences derived from this inaccurate or erroneous information.

7. WITH WHICH RECIPIENTS WILL USER DATA BE SHARED?

User data may be communicated to:

– Public Administrations with jurisdiction in the matter.
– Courts and Tribunals, in case of specific requirements made in accordance with the applicable regulations.
– State Security Forces and Bodies, in case of specific requirements made in accordance with the applicable regulations.
– ECOEMBES ENTIDAD ADMINISTRADORA, S.L.U., for centralised administrative management purposes, said communication being protected by the legitimate interest of ECOEMBES recognised in Consideration 48 of the RGPD.

Additionally, the data may be accessible by ECOEMBES suppliers, such access being necessary for adequate compliance with legal obligations and/or the purposes indicated above. These providers will not process your data for their own purposes that have not been previously informed by ECOEMBES. ECOEMBES will contract the provision of services by third parties who carry out their activity, by way of example and not limitation, in the following areas: cloud or computer hosting, sending commercial communications, legal advice.

In this sense, ECOEMBES follows strict criteria for the selection of service providers in order to comply with its obligations regarding data protection and undertakes to sign a processing agreement, as established by law, by which will impose, among others, the following obligations: apply appropriate technical and organizational measures to guarantee the security of personal data; process personal data for the agreed purposes and in accordance only with the documented instructions of the controller; and delete and return the data to the data controller upon completion of the services.

Some of our service providers are located in countries outside the European Economic Area (“EEA”).

The location of these companies outside the EEA implies the existence of an international transfer of your personal data. However, at ECOEMBES we have applied measures so that these transfers do not lead to a lower degree of protection of your personal data.

In this sense, service providers located outside the EEA have signed the corresponding standard contractual clauses approved by the European Commission (“CCT”), an agreement signed between both entities by which the non-EU company guarantees that it applies European standards. Data Protection. Likewise, many of these providers are certified and adhere to the Data Privacy Framework endorsed by the European Commission.

Therefore, the use of these providers does not give rise to a lower degree of protection of your personal data than that which would result from the use of providers located in the European Union.

You can request a copy of these CCT from us by sending your request to the address oficinadeprivacidad@ecoembes.com.

8. COMMUNICATIONS

Law 34/2002, of July 11, on information society services and electronic commerce, allows commercial communications to be carried out through the use of the Internet and other electronic means, provided that they can be identified as such, as well as the entity from which they are made.

ECOEMBES will send commercial communications via email about similar services that are of interest to the user.

However, ECOEMBES will offer the recipient the possibility of opposing the processing of their data for promotional purposes, both at the time of data collection and in each of the commercial communications sent to them.

Users may unsubscribe from these communications by writing to the registered office of ECOEMBES indicated above or to the following email address oficinadeprivacidad@ecoembes.com, indicating “unsubscribe from commercial communications.”

9. ECOEMBES PROFILE ON SOCIAL NETWORKS

ECOEMBES has a presence on several social networks. When you interact with any of our pages on social networks, the processing of data will be governed by the conditions of use, privacy policies and access regulations that belong to the corresponding social network and previously accepted by the user.

ECOEMBES will process your data in order to correctly manage its presence on the social network, informing you of activities, products or services, as well as for any other purpose that the regulations of social networks allow.

Please note that we have no influence over the information that the social network collects or how it processes it.

10. DATA CONSERVATION

ECOEMBES will retain the personal data of users only for the time necessary to achieve the purposes for which they were collected. Subsequently, if necessary, ECOEMBES will keep the information blocked until the legal responsibilities that may have arisen as a result of the processing of users’ personal data expire, at which time it will be irreversibly deleted.

1. Adequate attention and management of requests made through the enabled forms: the data will be kept for the period necessary to process and respond to your request and, once completed, blocked during the limitation period of the actions. legalities derived from the aforementioned request.

2. Submission, by electronic means, of information related to activities related to the Circular Packaging Challenge program: the data will be kept as long as the user does not revoke the consent given for this purpose or opposes the processing and, once revoked or opposite, blocked during the limitation period of legal actions that may arise from it.

3. Manage your registration in the Circular Packaging Challenge program: the data will be kept as long as the relationship with ECOEMBES is maintained and, once completed, blocked during the prescription period for legal actions that may arise from its use.

4. Sending satisfaction surveys: the data will be kept as long as the user does not object to the processing and, once they have objected, blocked during the statute of limitations of any legal actions that may arise from it.

5. Data provided for the exercise of rights: the data will be kept for the period necessary to manage and process the rights exercised and, once it has ended, during the period of prescription of legal actions that may arise from the contractual relationship.

6. Data derived from the use of the Website: the data will be kept for a period of two years or until the user objects. ECOEMBES may maintain the information in aggregate form, without identifying the users, for a longer period of time.

11. USER RESPONSIBILITY

The user:

• You guarantee that you are over fourteen (14) years old and that the data you provide to ECOEMBES are true, accurate, complete and updated. For these purposes, the user is responsible for the veracity of all the data communicated and will keep the information provided appropriately updated, in such a way that it responds to their real situation.

• You guarantee that you have informed the third parties of whom you provide your data, if you do so, of the aspects contained in this document. Likewise, you guarantee that you have obtained your authorisation to provide your data to ECOEMBES for the stated purposes.

• You will be responsible for any false or inaccurate information provided through the Website and for any direct or indirect damages that this may cause to ECOEMBES or third parties.

12. EXERCISE OF RIGHTS

As the owner of the data, the user can send a letter to ECOEMBES, to the address indicated in the header of this Privacy Policy, or by email to the address: oficinadeprivacidad@ecoembes.com, proving their identity, at any time and free of charge, to exercise the following rights:

a) Right of access:

You will have the right to be informed by ECOEMBES about whether or not it is processing your personal data and, in such case, to be able to access said data and receive information about the purposes for which it is processed, the categories of data affected by the processing, the recipients to whom your personal data was communicated and the expected period of conservation of the data, among other information.

b) Right to rectification and deletion:

You will have the right to request the deletion of personal data provided that legal requirements are met, and the rectification of inaccurate data that concerns you when, among other reasons, it is no longer necessary for the purposes for which it was collected.

c) Limitation of treatment, revocation of consent and total or partial opposition to treatment:

In certain circumstances (for example, in the event that the applicant disputes the accuracy of their data, while their accuracy is verified), they may request that the processing of their personal data be limited, with these only being processed for the exercise or the defense of claims.

You will also have the right to revoke the consent given and oppose the processing at any time, for reasons related to your particular situation, if the processing is based on our legitimate interest. In this case, ECOEMBES will cease processing, unless legitimate reasons are proven.

d) Portability of your data:

You will have the right to receive the personal data that you have provided to ECOEMBES in a structured, common and machine-readable format, and to be able to transmit them to another person responsible for the treatment without the person responsible to whom you have provided them preventing you from doing so, in the cases legally provided for these purposes.

e) Automated individual decisions:

Likewise, in addition to the aforementioned rights, in the event that automated decisions are made, including profiling, you will have the right to obtain human intervention from ECOEMBES and to express your point of view and challenge the decision.

f) Others:

Likewise, when personal data is transferred to a third country or an international organisation, you will have the right to be informed how you can access or obtain a copy of the appropriate safeguards relating to the transfer.

Likewise, you may file a claim regarding the protection of your personal data before the Spanish Data Protection Agency at the address C/ Jorge Juan, 6, 28001 – Madrid, when the interested party considers that ECOEMBES has violated the rights that are recognised by the applicable data protection regulations.

13. SECURITY MEASURES

ECOEMBES will treat the user’s data at all times in an absolutely confidential manner and maintaining the mandatory duty of secrecy with respect to them, in accordance with the provisions of the applicable regulations, adopting for this purpose the necessary technical and organisational measures that guarantee the security of your data and prevent its alteration, loss, treatment or unauthorised access, taking into account the state of technology, the nature of the stored data and the risks to which they are exposed, whether they come from human action or the physical or natural environment.

14. CHANGES

ECOEMBES reserves the right to review its Privacy Policy at any time it deems appropriate, in which case it will be communicated to users. For this reason, we ask you to regularly check this privacy statement to read the most recent version of the ECOEMBES Privacy Policy.

15. ACCEPTANCE AND CONSENT

The user declares to have been informed of the conditions on protection of personal data, accepting the content of this Privacy Policy.

Last update: January 2024.