Privacy Policy

This Privacy Policy seeks to inform you about how we process your personal data when you browse or use the services included on our website, so that you may freely decide whether you wish to provide said data for the purposes detailed in this document.
1.    Who is responsible for processing my personal data?

The entity responsible for the personal data we request from you is: JMA Alejandro Altuna S.L.U. with registered address at Bidekurutzeta Kalea, 6, 20500 ARRASATE/MONDRAGON, GUIPUZCOA, SPAIN (hereinafter, JMA).

If you would like to contact us, please do so at:

• The following email address: info@jma.es
• The following telephone number: +34 943793000

2.    How have my personal data been obtained?

The personal data that will be processed come from:

• Filling in the data fields contained in the forms published on the website.
• Cookies. Please consult our Cookies Policy for more information on this processing.

3.    Legal grounds for processing your personal data

The personal data processing we undertake is based on the following legal grounds:

a.    Consent from the data subject (Article 6.1.a GDPR)

• Whenever the user provides us with their data via contact forms, by subscribing to newsletters, by creating an account or by accepting the delivery of commercial communications.
• Said consent is always free, informed and can be withdrawn at any time, without such action affecting the lawfulness of any data processing prior to the withdrawal.

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

• Whenever the processing is necessary to manage contractual relations with the user: provision of services, processing of orders, billing, customer service, etc.
• Also in those cases where the user requests information prior to contracting a product or service.

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

• Whenever the processing is necessary for compliance with obligations under applicable legislation, such as:

- Tax and accounting obligations.
- Response to requirements from public or judicial authorities.
- Data storage for responding to potential legal liabilities.

d.    Legitimate interest of the data controller (Article 6.1.f GDPR)

• When the processing is necessary to meet legitimate interests, provided that the fundamental rights and freedoms of the user do not take precedence over said interests.
• Examples:

- To improve the quality of services and the browsing experience.
- To prevent fraud or improper use of the website.
- To conduct satisfaction surveys.

4.    How should my data be processed?

Your personal data will be processed according to the following principles:

• Principle of lawfulness, fairness and transparency: We will request your consent to process your personal data whenever legally necessary and we will clearly and transparently inform you of all issues related to the processing of your personal data, your rights and how to exercise them.
• Principle of data minimisation: We will only ask for those strictly necessary data that are adequate and relevant to the purpose for which they are collected.
• Principle of storage limitation: The personal data will be processed for as long as is strictly necessary for the purpose for which they were collected. The data will be permanently deleted once any legal liabilities stemming from the processing of the data have expired.
• Principle of integrity, availability and confidentiality: We apply security measures of a technical and organisational nature that are proportional to the risk and to the state of the art in order to guarantee the integrity, availability and confidentiality of your personal data.
   

5.    For what purpose will my personal data be processed?

Your personal data will be used for the following purposes:

• To respond to your request.
• When you contract any of our products and services, we will use your personal data to manage them and bill you for them.
• In the event that you provide your CV, we understand that you wish and intend for us to keep the same indefinitely for the purpose of including you in current or future recruitment processes, without prejudice to your right of cancellation or opposition, which you may freely exercise at any time.

6.    How long will my personal data be kept?

The personal data provided will only be kept for as long as is strictly necessary to meet the purposes for which they were collected, and as long as the user does not request the same to be erased. Specifically:

a.    Details of registered customers and users

• These will be kept for as long as the contractual relationship exists and, upon expiry thereof, for as long as necessary to respond to any potential legal liabilities (usually 6 years under current mercantile and tax regulations).

b.    Contact details (forms, queries, customer service emails)

• These will only be kept for as long as needed to respond to the request and for a maximum of 12 months for engaging in follow-up activities.

c.    Details for commercial communications and newsletters

• These will be kept for as long as the data subject does not withdraw their consent or request to be unsubscribed. The right of opposition or erasure may be exercised at any time.

d.    Details related to legal obligations

• Certain information must be kept for the necessary period to comply with tax, accounting or administrative obligations: usually 4 to 6 years under applicable regulations.

e.    Details of recruitment process candidates (if the website collects CVs)

• These will be kept for a maximum period of 24 months unless the candidate asks them to be erased earlier.

7.    What data must I provide?

All the personal data requested and marked with an asterisk are required for acquiring or contracting our products and/or services. If any of these required data are not provided, we will be unable to provide our products and/or services. 

8.    Will my personal data be shared with third parties?

Your data may be shared with companies within the Altuna Group, which can be found at www.jma.es, whenever necessary to respond to your request. If you are considered a customer, supplier, registered user, candidate or employee of Altuna Group, we inform you that we share information systems, commercial interests and management of common services between companies of the group. Hence, your personal data may be shared and processed by companies of the Altuna Group, always for legitimate and proportional purposes of a compatible nature with this professional relationship, without prejudice to your right of opposition.

9.    Your rights

• You have the right to access your personal data.
• You have the right to ask for your data to be rectified or deleted.
• You may withdraw the consent granted at any time.
• You may ask for restrictions to be placed on the processing of your personal data.
• You have the right to oppose the processing of your personal data.
• You have the right to personal data portability.

To exercise any of these rights, you must send a request to the address of the data controller indicated in the first section of this privacy policy. Please remember that the request must be submitted by the data subject themselves. If you would like further information about your rights or how to exercise them, you may also contact the Spanish Data Protection Agency [Agencia Española de Protección de Datos] at www.agpd.es.

10.    Cookies

We inform you that JMA has cookies installed on your systems for the sole purpose of improving and personalising the service offered, as well as to facilitate browsing. The cookies are only associated to an anonymous user and a computer, and no access is possible to personal data. Cookies are small text files stored by the browser on your computer's hard drive. When you browse our website, our server may recognise the cookies and provide us with information on the language selected during your last visit. Most browsers automatically accept the use of cookies, although you can configure your browser to provide on-screen alerts about incoming cookies and prevent them from being installed on your hard drive.

More information on cookies can be found here: Cookies Policy

11.    Data quality

The User guarantees that the personal data provided to JMA are accurate, and undertakes to communicate any changes thereto. The User will be exclusively liable for any damages, whether direct or indirect, that may be incurred by JMA or any third party as a result of completing the forms with false, inexact, incomplete or out-of-date data. The User must not include personal data of third parties without their prior informed consent regarding the content of this privacy policy, and is exclusively liable for the inclusion thereof.

12.    Confidentiality

Your personal data are classified as confidential information. Hence, all processing of these data will take place while guaranteeing the utmost level of secrecy vis-à-vis third parties and applying the necessary security measures to guarantee the security thereof.

13.    Security measures

JMA has adopted all those measures necessary to prevent the alteration, loss, processing or unauthorised access to personal data, while at all times bearing in mind the state of the art, the nature of the data stored and the risks to which they may be exposed, whether that be due to human action or the physical or natural medium. However, the User should be aware that Internet security measures are not impregnable.

14.    Specific Terms and Conditions

Certain services provided by JMA may contain specific terms and conditions with specific provisions on personal data protection. As a result, any specific terms and conditions will take priority in each case. Anything not governed by specific terms and conditions will be governed by the general terms and conditions contained in this privacy policy. 

15.    Consent

Please note that children under 14 must have permission from their parents or legal guardians to provide personal data on the JMA website.