سياسة الخصوصية

The security of personal data has become one of the top priorities for organisations, and in ACCIONA Cultural Engineering, S.A.U., guaranteeing the inviolability of this information has to take top priority. In this regard, we want to be transparent and ensure that this Privacy Policy is at the disposal of all those who interact with us.

This policy applies to ACCIONA Cultural Engineering, S.A.U. and all the companies in its Group, (referred to collectively as “ACCIONA”), detailed below. Any references in this Privacy Policy to “ACCIONA”, “us”, “we” and ”our” concern the entity responsible for processing your personal information that, generally speaking, will be that which gathers and processes and at any time identifies this information. This Policy has a global character since, although whenever we collect your data, we shall provide you with specific information on the processing.

ACCIONA undertakes to process the personal data in accordance with Regulation (EU) 2016/679, 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, and other legislation in force on Data Protection.

This Privacy Policy applies to all Users, understood to mean those who visit the website and any other person who suppliers their personal data for use via the different channels (“User” or “Users”). In this context,  with Channels we understand to be a reference to the various means or services that we make available to you so the User can interact with us, whether or not they involve registration, such as webs, applications, platforms, mailboxes, addresses or User information or assistance telephone numbers, social media profiles, forms, events, etc.

Some of our on-line Channels may contain links to other third-party websites and applications not related to ACCIONA. This Privacy Policy does not apply to the same. Please also revise the Privacy Policies of such third parties with a view to familiarising yourself with their practices. They may also contain third-party cookies that are not owned or controlled by ACCIONA. In this case, you can choose your third-party cookies configuration using our Cookies Configuration Tool, situated at the bottom of the website, where you will be able to manage your preferences and which you can access by clicking on “Cookies”.

ACCIONA  adopts the technical and organisational measures necessary to guarantee the security of personal data and avoid any alteration, loss, unauthorised processing or access, according to the state of the art, the nature of the data and the risks to which it is exposed. You can also verify the presence of the SSL certificate by checking the Page properties in your browser. A connection will be secure when the address bar of the browser displays “https://” instead of “http://” and the padlock symbol appears. You can consult further characteristics of the SSL certificate in the Legal Notice section.

WHO IS RESPONSIBLE FOR PERSONAL DATA PROCESSING?

Whenever personal data are collected and processed, we shall inform the User of the ACCIONA company which is the Data Controller in charge of processing, and we shall provide the corresponding identifying data.

With regard to this Privacy Policy and this website, we inform you that the data controller is:

• Company name: ACCIONA Cultural Engineering, S.A.U.
• Tax ID no.: A41404351
• Address: Avenida de Europa, número 18, Parque Empresarial de la Moraleja, 28108 Alcobendas (Madrid).
• Telephone: +34 91 0470624
• Email:  info.ce@acciona.com

With regard to the events of design and production worldwide, we inform you that the data controller could be ACCIONA Cultural Engineering, S.A.U. or ACCIONA Ingeniería Cultural, S.L.

• Company name: ACCIONA Ingeniería Cultural, S.L.
• Tax ID no.: B-82234451

• Address:Avenida de Europa, número 18, Parque Empresarial de la Moraleja, 28108 Alcobendas (Madrid).
• Telephone:+34 91 0470624

• Email:  info.ce@acciona.com

The User will be able to contact the Data Protection Department to clear up any queries he/she may have regarding the processing of personal data at the postal address provided above or at the following email protecciondedatos@acciona.com

WHAT DATA CAN WE RECEIVE VIA OUR CHANNELS?

For the purposes of this Privacy Policy, “personal data” refers to the data which identifies a person or can be used to identify them.

ACCIONA informs its Users that personal data, obtained via the Channels it owns or holds, will only be gathered for processing when appropriate, pertinent and not excessive in relation to the specified, explicit and legitimate ambit and purposes for which it was obtained.

When, via our Channels, personal data is gathered for specific purposes, the User will be informed clearly and unequivocally in advance of i) the controller and its contact details, iii) the purposes of the specific processing and the legitimacy for it, iv) the recipients or categories of recipient, if applicable, as well as the existence of international transfers, if any, v) the storage criteria or terms, and vi) their rights as an interested party.

The User is also the only person responsible for the information supplied and for the veracity and lawfulness of the same.

• Information on third parties

When the User provides data in relation to third persons, whether voluntarily or because we request it in order to comply with a legal obligation, the User consents to the processing and declares that the data is accurate. Likewise, the User declares that it has specifically informed third persons of the content of this policy and/or any other applied, and of the corresponding rights with regarding to Personal Data Protection. The above notwithstanding, ACCIONA will use its best endeavours to act properly in relation to processing of such third parties.

• Public information

ACCIONA may process that information to which it has access as information that is lawfully available to the public and, in particular, any public information available in official registries. In any event, this processing will only take place if there is a legitimate basis as set out in the applicable legislation and, whenever it is possible or a contractual relationship exists, will be informed.

Personal data of minors

ACCIONA does not deliberately gather personal data of minors, without the authorisation of their parents, representatives or legal guardians. None of the Channels offered to Users by ACCIONA are designed for or directed at minors.

If parents, representatives or legal guardians consider that their underage children have supplied personal information without their consent, we ask that they contact us at the following email protecciondedatos@acciona.com.

WHAT IS THE PURPOSE AND LEGITIMACY OF PERSONAL DATA PROCESSING BY ACCIONA?

ACCIONA processes the personal data of the Users, gathered via any of our Channels, for the purposes and on the legitimate bases as set out in detail and notified for each specific processing operation; however for your information only, we have set out some of these, which are more general in scope, below:

• Manage the relationship established with us
  • In those services we provide via APPs or web platforms, we process the data supplied by Users with the purpose of managing access credentials, providing assistance, responding to enquiries and administering our products and services.
  • In this sense, we also process the data for the purpose of catering for requests for services and information from our Users received via any of our Channels, as well as for processing any suggestions, claims or complaints.
  • We can process User data for satisfaction surveys regarding our services.

In all of these cases, the legal basis for the processing is the execution of a contract or pre-contractual measures and/or the maintenance of the relationships established with ACCIONA.

• • We shall also process your data whenever you subscribe to any of our channels, newsletters or news bulletins alerting you to our products and/or services, or ask us to send you commercial communications, and the data you provide us with through the cookies collected when browsing online.

In these cases, the legal basis for the processing is the consent given by the User.

• Manage contact details in the context of contractual or commercial relations

We process contact details of potential customers; legal representatives of legal persons and bodies, whether public or private; analysts and investors; or other parties intervening, who supply their data, with a view to sending them information of interest, managing the commercial relationship between us, managing invitations or notices regarding events organised or sponsored by ACCIONA or in which it participates.

The legitimacy is maintaining the contractual and/or commercial relationship between us, or where there is none, the consent stated by the User in providing contract details.

• Compliance with the legal obligations that affect us.

Whether these legal obligations are of a commercial, tax, accounting or administrative nature; the legal basis entitling us to process data is compliance with legal obligations.

• Fraud management

In some of the services we provide, it is necessary to verify identity in order to offer protection, detect and prevent fraud or other unlawful activities, unauthorised transactions, claims and other kinds of responsibilities, as well as to manage the quality and risks associated with the business; and investigating where necessary, any unlawful activities and potential breaches of our policies and/or the conditions of our services.

The legal basis is compliance with the applicable legal obligations in each case. Among others and by way of example, Act 10/2010 of 28 April on the Prevention of Money Laundering and Terrorist Financing.

• Security and surveillance of premises

Our premises have cameras and video-surveillance systems in order to ensure the security of assets and persons.

The legitimacy for processing is the legitimate interest of ACCIONA in guaranteeing security in its premises.  

• Managing visits and third parties

With a view to monitoring access to the premises by visitors, collaborators or other third parties, it is possible that identification details will be gathered at some premises.

The legitimacy in this case is the consent given as well as ACCIONA’s legitimate interest in guaranteeing the security of assets and persons in its premises.

FOR HOW LONG DOES ACCIONA STORE THE USER’S PERSONAL DATA?

In general terms, the data will be stored (i) for the time necessary for the purpose for which it was gathered, (ii) for the applicable expiry terms, in case liabilities derived from the processing arise.

In particular:

• Data gathered to process requests or enquiries will be stored for the time necessary to respond to the same, but never for longer than twelve months.
• Data gathered based on your consent will be stored unless it is withdrawn.
• In all other cases, the User will be informed of the storage terms applicable to the specific processing.

TO WHOM CAN ACCIONA DISCLOSE THE USER’S DATA?

At ACCIONA, we undertake not to assign or disclose the personal data of our Users except where described in this Privacy Policy or, if applicable, at the time the data is gathered.

• We may exchange personal information with service providers which are ACCIONA companies or third parties, in some cases hired to provide services on our behalf. In these cases, where necessary, the corresponding processing agreements will be signed in accordance with the regulations on data protection.
• We reserve the right to transfer to a third party any information we have on Users in the event of an actual or potential transfer or sale of all or part of our business or assets (including mergers, acquisitions, joint ventures, restructurings, assignments, dissolution or liquidation) or other structural or commercial operations. In that case, such third parties will be required to ensure levels of protection that are comparable to those provided by ACCIONA in relation to the information to be shared.
• We can disclose your personal information (1) to courts and tribunals or administrations in the exercise of their administrative powers and powers, if we are permitted or required to do so by law or by a process of law (such as a court order or subpoena); (2) to the police authorities or other public officials in order to comply with a legal, legitimate request; (3) when we consider it necessary to avoid physical harm or financial loss; (4) in order to establish, exercise or defend our legal rights; (5) in relation to the investigation of a suspected or proven case of fraud or unlawful activity; or (6) with Users’ express and informed consent.
• Likewise, ACCIONA informs that some of its service providers, third parties or Group companies may be located outside of the European Economic Area in territories that do not offer a level of data protection that is comparable to that of the European Union. In such cases, we transfer User data with appropriate safeguards and always ensuring the security of the same, such as the formalisation of Standard Contractual Clauses of the kind approved by the Commission, the content of which can be consulted via the following link: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

SOCIAL MEDIA

At ACCIONA we use social media such as LinkedIn, Twitter, Facebook, Google+, Instagram or YouTube, to share our content. We act as data controller for the data we publish online, processing it always in accordance with the conditions established for each of the social media outlets.

Interaction with Users due to the use of such profiles or tools may imply an international data transfer, of an analytical and technical nature, in relation to the Website and the social media profiles, with the data supplied by Users via such profiles being processed on the servers of the social media companies.

 DIRECT MARKETING

Generally speaking, ACCIONA does not use the personal data of Users for direct marketing purposes, unless express and informed consent is obtained in advance.

Users can, at any time, opt out of any direct marketing campaigns and oppose the future transfer of their personal data for such purposes, sending us an email to the address of the Data Controller using the corresponding “unsubscribe” option, included in the communication method.

AUTOMATED DECISIONS

At ACCIONA we do not carry out automated decision-making, nor does it create profiles.

PERSONS ATTENDING EVENTS ORGANISED BY ACCIONA

At any acts, training sessions, meetings, initiatives, etc. (“Events”), organised or promoted by ACCIONA, in its premises or elsewhere, we may ask the User to supply personal data in order to duly manage such Events and attendance at the same. This data may, among other things, be related to managing access, accreditation, transport and travel, accommodation, catering, delivery of related documentation, etc. This processing will be based on consent and, in certain cases, on fulfilment of a contractual relationship or legal obligation.

This data may have to be disclosed to some of the service providers or collaborator or sponsor entities, participating or intervening in the Event, of which the user will be conveniently informed in each case. As a general rule, we will only store this information for the time strictly necessary to hold the Event and, if appliable, to comply with any applicable expiry deadlines.

• Image: In addition to the processing derived from the security and surveillance of our premises, as a result of User participation in Events, their image and, on occasion, their voice may be recorded and processed by ACCIONA in the form of photographs and/or video recordings. Whenever the Events involve this processing, we will inform the User expressly. This processing may be for internal, external and/or Event promotion purposes, meaning that the material may be used for reproduction, distribution, transformation, public communication, recording and placing at disposal in any format or medium (including, but not limited to, exploitation via analogue or digital media and via the Internet, such as websites or intranets belonging to ACCIONA entities) without such activities granting a right to remuneration, consideration or any other financial benefit for the User.

This processing is based on consent, whether individually and expressly granted, where possible, by the User, or due to attendance at Events in relation to which the User was informed of image processing in advance. The authorisation of the User will be worldwide in scope, transferrable  and for the duration of the intellectual property rights. The User may revoke consent at any time, via the appropriate Channels.

The intellectual and industrial property rights of materials generated in the context of Events and activities correspond exclusively to ACCIONA.

WHAT ARE THE USER’S RIGHTS WHEN WE PROCESS HIS/HER DATA? 

The User can exercise his/her rights of access, correction, erasure, data portability, and/or the limitation of or opposition to processing, before the corresponding data controller, or by writing to the Personal Data Protection Department at C/ Anabel Segura, 11, Edificio C,  28108 Alcobendas (Madrid), or by sending an email to: protecciondedatos@acciona.com. If we consider it necessary in order to be able to identify you, we may ask you for a copy of an identity document.

Likewise, you may withdraw consent at any time by writing to the address indicated above, as well as by presenting a complaint to the corresponding Supervisory Authority on data protection and, in particular, to the Spanish Data Protection Agency (www.aepd.es).

Remark: During exceptional periods such as States of Alarm or Emergency, implying periods of lockdown or other external disturbances such as natural disasters, extreme climate events or wars, the rights not exercised via email and exercised by standard post will involve a longer than usual time of reply, with the times of reply being restored when the recommended lockdown period has ended.

RELATED INFORMATION 

Below is a series of links where you will be able to obtain further information that may be useful in relation to other personal data processing. You can also obtain information on the website in the Legal Notice. 

• ACCIONA

The User can obtain further information on the processing of personal data of ACCIONA at https://www.acciona.com/privacy-policy/

• Applicants 

Any interested party can apply for job vacancies, scholarships and/or specific programmes through our Employment Channel. You can consult the information on this processing is available at: https://mediacdn.acciona.com/media/kkcjzq2f/politica-privacidad-candidatos-en.pdf

• Ethical channel 

We have a reporting channel, known as the Ethical Channel, in which both employees and providers or third parties can confidentially report any breach of which they are aware. You can consult the complete information regarding this treatment at https://www.acciona.com/shareholders-investors/corporate-governance/rules-governance/compliance/

• Suppliers

https://acciona-procure.bravosolution.com/web/data_protection.html

VALIDITY

Any change to the Privacy Policy and in the information administration practices will be duly reflected and ACCIONA will add to, modify or replace this Policy when it considers it necessary.

This Privacy Policy is published in Spanish and English; in case of any discrepancy between the two versions, the Spanish version will prevail.

Last update:  June 22, 2021