The purpose of this Privacy Policy is to provide information on how “TRACEABLE LUXURY SERVICES, S.L.” processes your personal data in accordance with the current regulations on personal data protection, specifically Regulation 2016/679 of the European Parliament and Council of April 27, 2016, regarding the protection of natural persons with respect to the processing of personal data and the free movement of such data (hereinafter, “GDPR”) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights (hereinafter, “LOPDGDD”).

I. DATA CONTROLLER

Who is responsible for your personal data?

The controller of your personal data is “TRACEABLE LUXURY SERVICES, S.L.”, a Spanish company with Tax Identification Number (N.I.F.) B-67.613.166, registered in the Commercial Registry of Córdoba, Volume 2,771, Folio 95, Sheet CO 42.004, Entry 2 (hereinafter, the “Data Controller”).

Contact details of the Data Controller are as follows:

– Address: Córdoba, Carretera Palma del Río, km. 3.3, Parque Joyero de Córdoba, Fase 20, Commercial Premises LC-158.
– Phone: +34 610 051 456.
– Email: gdpr@tracemark.tech

II. PURPOSES OF DATA PROCESSING

For what purposes do we process your data?

The Data Controller will process your data in a lawful, fair, and transparent manner, whether by automated means or not, for the following specific and explicit purposes:

1. Handling any queries, complaints, or requests for information.
2. Providing membership services; software exploitation license services; and traceability services under the Tracemark Protocol, where the traceability of jewelry is shown throughout the supply chain (from mining companies to the final consumer) and the manufacturing process of jewelry.
3. Issuing invoices for services provided and managing the payment collection.
4. Conducting satisfaction surveys about the services rendered.
5. Inviting you to meetings, conferences, conventions, and commercial and corporate events.
6. Sending newsletters with commercial and corporate news.
7. Identifying you and contracting you as a user, member, or partner.
8. Managing all legal and administrative procedures related to company personnel, formalizing contracts, handling payroll, social security, occupational health and safety, and training.
9. Handling your application for participation in our recruitment processes and job offers.
10. Ensuring the safety of people, property, and facilities.

III. LEGAL BASIS FOR PROCESSING

What is the legal basis for processing your data?

The legal bases for the purposes outlined in the previous section are as follows:

1. Execution of a contract: For labor relations with employees and commercial relations with clients and suppliers.
2. Application of pre-contractual measures: For commercial relationships with potential clients.
3. Explicit consent: For the recruitment process of job candidates, sending satisfaction surveys, newsletters, and invitations to meetings, conferences, conventions, and commercial and corporate events (for each of these purposes, your prior explicit consent will be required).
4. Legitimate interest: For responding to queries submitted via the contact form on the website.
5. Legal obligation: For compliance with labor law, occupational health and safety, and ARCO+ rights (access, rectification, cancellation, opposition, portability, limitation of data processing, and non-automated decision-making) of data subjects.
6. Public interest: To ensure the safety of people, property, and facilities.

IV. CATEGORIES OF PERSONAL DATA

What categories of personal data are processed?

The Data Controller will request only the information that is appropriate, relevant, and strictly necessary for the purposes for which it is processed.

The categories of data processed include:

1. Identification data: Name, surname, ID number, address (postal and electronic), signature, image, phone number, and user credentials.
2. Special categories of data: Health data (related to medical leave, workplace accidents, and disability level, excluding diagnoses).
3. Personal characteristics: Gender, marital status, nationality, age, date, and place of birth.
4. Attendance control data: Entry and exit records and reasons for absence.
5. Academic and professional data: Qualifications, education, and professional experience.
6. Financial data: Bank account details.

V. RECIPIENTS

Who can your data be shared with?

Personal data may be disclosed to:

– Competent public bodies, tax and social security authorities, courts, and tribunals, as required by tax, labor, commercial, or social security regulations.
– Data processors, such as service providers to the Data Controller (e.g., hosting companies, web platforms, payroll processors, occupational risk prevention services, communication delivery services).

No international data transfers are currently made. The website’s servers are located on Microsoft Azure servers in France, within the European Economic Area (EEA).

VI. DATA RETENTION PERIOD

How long do we keep your data?

Personal data will be retained for as long as necessary to fulfill the purposes for which it was collected and for as long as the business or labor relationship is maintained. Once the relationship has ended, data will be kept for the relevant statute of limitations.

VII. DATA SUBJECTS’ RIGHTS

You have the following rights:

1. Right to access your personal data.
2. Right to rectify inaccurate or incomplete data.
3. Right to erasure of your data.
4. Right to restrict processing of your data.
5. Right to data portability.
6. Right to object to the processing of your data.
7. Right not to be subject to automated decision-making.
8. Right to withdraw consent at any time.

To exercise these rights, you may contact “TRACEABLE LUXURY SERVICES, S.L.” in writing at the address provided or via email at gdpr@tracemark.tech. You can also file a complaint with the Spanish Data Protection Authority.

VIII. CHILDREN’S USE POLICY

The website is not intended for children under sixteen (16) without parental consent.

IX. SECURITY MEASURES

The Data Controller will implement appropriate technical and organizational measures to ensure the integrity, confidentiality, and availability of your data.

X. MODIFICATIONS TO THE PRIVACY POLICY

This Privacy Policy may be modified at any time by publishing the changes on the website.

© 2020 TRACEABLE LUXURY SERVICES, S.L. All rights reserved.