Data protection policy

The management of ANOVO is committed to complying with current legislation on data protection, and for that reason we have drawn up this data protection policy.

ANOVO is committed to promoting compliance with the principles of active responsibility established under the General Data Protection Regulation (hereinafter GDPR) through a process of continuous improvement, aimed at:

• Handling personal data in a licit, lawful and transparent manner regarding data subjects.
• Using personal data only and exclusively for the purposes foreseen for each handling. Under no circumstances may data be used for distinct or incompatible purposes.
• Analysing the legal bases for handling and obtaining the consent of data subjects in cases where such consent is necessary for the handling.
• Handling as little personal data as is necessary for the purpose for which it was collected.
• Keeping personal data up to date and accurate. In cases where data are found to be inaccurate, they should be updated or deleted.
• Keeping personal data for the minimum time necessary for the purposes of the handling, in accordance with the legally established retention periods.
• Maintaining at all times the confidentiality, integrity and availability of the personal data we handle.
  This commitment leads to the following:
• Providing the necessary resources and establishing the necessary objectives for the correct implementation and continuous improvement of information security and the protection of the personal data we handle.
• Promoting and implementing appropriate measures to ensure the training, education and awareness of all staff in information security and data protection.
• Establishing appropriate risk assessment criteria for the risks to which the handling is exposed so that all risks that are not at an acceptable level are adequately dealt with until an acceptable residual risk level is attained.
• Drawing up and maintaining activity records for all handling carried out.
• Establishing procedures to prevent data security breaches and providing rapid notification in the event of such breaches.
• Appointing a Data Protection Officer and respecting their impartiality and independence in the exercise of their functions.

Information regarding the data we handle

In accordance with our data protection policy we will endeavour to inform you in a clear and understandable way regarding the handling that we carry out at ANOVO regarding the data that we have in our systems, either because it has been provided to us directly by the interested parties by any means (through this website, email, telephone or by any other electronic or manual means) or because their data has been provided to us by manufacturers and operators in connection with a request for a repair or service.

Identity of those responsible

We hereby notify you that the identity of the persons responsible for handling the personal data you have provided us with by any means are as follows:
ANOVO COMLINK ESPAÑA S.L. bearing Tax Identification Code B-92192665 (ANOVO) and based at C/ Charles Darwin s/n, 29590, Campanillas, Málaga. Telephone: +34 952020020 and email: comunicacion@anovo.es

ANOVO IBÉRICA MADRID S.L. with CIF B82479197 (ANOVO) and address at C/ Isla de Alegranza, naves 15-16, 28703 San Sebastián de los Reyes, Madrid, contact telephone number: 916258080 and e-mail: comunicacion@anovo.es.

Hereinafter we will refer to the group of companies we have described in the identity of the persons responsible as ANOVO.

Contact details of our Data Protection Officer

We hereby notify you that you can contact the Data Protection Officer at ANOVO via the following address: dpd.spain@anovo.es.

Purpose of the handling

At ANOVO we handle the data provided to us only for the purposes foreseen in each handling or form or request for services that you have entrusted to us. We do not handle the data you have provided to us for a specific purpose for any different purpose unless you have made several requests or have given us your express consent in a clear and affirmative manner.
In this sense, the data you have provided in order that we provide you with the repair services or replace your appliance, will be handled for the purpose of correctly carrying out the repair services, traceability and quality control covering the contracted services, in addition to communication by the means you have provided us with (telephone or e-mail) regarding the status of the repair and a subsequent survey regarding the quality of the services provided.
The data you have provided us with in order to make an enquiry will be handled in order to reply to you (provided that you have given us truthful data) regarding the enquiry you have made by the means you have provided us with (telephone, e-mail or land mail).
The data you have provided to us so that we can send you advertising and commercial information will be used for this purpose and we will proceed to send you this information by the means you have provided us with (telephone, e-mail or land mail).
We hereby notify those who send us their Curriculum Vitae (CV), that their data will be treated with complete confidentiality and will be used only and exclusively in the personnel selection processes that ANOVO may carry out.

Handling in the ethical channel

The purpose of the handling is to establish a communication channel so that any person can lodge a complaint or make enquiries regarding irregularities, breaches or acts contrary to the rules and principles of action of the Criminal Compliance Policy.

This handling is based on compliance with obligations regarding the supervision of the operation of and compliance with the criminal risk prevention model set out in article 31 bis of the criminal code.

The data contained in complaints submitted shall be deleted at the latest 3 months after their submission if not leading to disciplinary or judicial proceedings, and in the event that the data lead to judicial proceedings, they shall be kept for the duration of such proceedings and/or liabilities may arise therefrom.

The data may be communicated to law enforcement agencies and to the Courts and Tribunals in the event that a penal or criminal offence is observed.

Interested parties have the right to obtain confirmation as to whether at ANOVO we are handling their personal data and therefore have the right to access their personal data, rectify data that is inaccurate or request its deletion when the data is no longer necessary for the purposes for which it was collected. To do so, they must contact ANOVO by e-mail at the address lopd.spain@anovo.es or by post, and in any event must prove their identity by means of an identification document. In addition, they are hereby notified that they have the right to file a complaint with the Spanish Data Protection Agency (www.aepd.es) and, in advance, with ANOVO’s Data Protection Delegate at dpd.spain@anovo.es.

Data retention policy

The data provided will be retained for as long as the commercial and contractual relationship with our customers and suppliers is maintained or for as long as is necessary to comply with legal obligations. Once this obligation has ended, we will delete the data in order to minimise the risk through having it available on our systems.
Data held for commercial communication purposes will be retained until the data subject exercises their right to data deletion.
CVs submitted by interested parties will be stored until a recruitment process takes place. In the event that we have a selection process open, they will be kept until the post applied for is filled.

Planned data communication

The data will be passed on to any of the companies belonging to the ANOVO GROUP that may be involved in the provision of the repair service, and to the manufacturers of the repaired product for quality control covering the services provided. It shall also be passed on to the entities to which it is necessary to pass on the data for the correct and complete provision of the repair service, such as the logistics service companies responsible for the removal and delivery of the equipment, or the companies acting as depositories that provide the customer with the delivery and subsequent collection of their equipment once the service has been provided.
Data for marketing communication may be passed on to companies we contract for electronic communication or marketing services.
The details of persons wishing to work at ANOVO may be passed on to the companies within the ANOVO group that have been indicated in the identification of those responsible so that they can take part in the selection processes that any of the companies may carry out.
At ANOVO we have contracted the services of news and electronic communication by email with the MailChimp platform, which processes data outside the European Union. Such international transfer of data is done through the use of standard contractual clauses (SCC) to ensure there is an adequate level of protection and that the international transfer of data is done through adequate safeguards in accordance with Article 46 of the GDPR.

Legal bases of handling

At ANOVO we take particular care to analyse the lawfulness of all the handling we carry out. In this regard, handling is carried out either because there is a contractual relationship in the case of contracts signed with our customers and/or suppliers, or because the data subjects have given us their consent for a request to repair their product or because we are subject to a service provision contract to repair their customers’ products.
In the case of commercial communication, the interested parties have had to give us their consent in a clear and affirmative manner so that we can keep their data and perform these commercial actions.
In the case of persons who voluntarily send us their CVs for the personnel selection processes that ANOVO may carry out, the very fact of sending us their CV is the legal basis for handling, as by sending it to us they are giving us their consent.

Security measures

At ANOVO we are concerned at all times to maintain the confidentiality, integrity and availability of the information we handle, and to that end we use international standards regarding compliance with these measures (ISO/IEC 27001 and ISO/IEC 27002). In that regard, we are committed to establishing appropriate criteria for assessing security risks and risks to the rights and freedoms of natural persons, to address those risks and to establish plans for their management, in order to reduce them to acceptable levels.

International data transfer

At ANOVO we carry out international data transfers by using the MailChimp email communications platform which hosts the data outside the EU. Such international data transfer is carried out under the use of standard contractual clauses (SCC), so that an adequate level of protection is guaranteed in accordance with Article 46 of the GDPR.

Rights of data subjects

You have the right to obtain confirmation as to whether at ANOVO we are handling your personal data and therefore you have the right to access your personal data, rectify inaccurate data or request its deletion when the data is no longer necessary. You also have the right to restriction of handling which allows the handling of your data to be stopped, so that your data is only kept under appropriate blocking measures for the exercise or defence of possible claims. Likewise, the portability of their data, which will allow data subjects to have us pass on their data in a structured, commonly used and machine-readable format to another data controller of the data subject’s choice.
The procedure established by ANOVO for data subjects to exercise their rights mentioned in the previous paragraph is to send an e-mail to the address lopd.spain@anovo.es or by land mail if they do not have an e-mail address. The data subject must in any event prove their identity by means of an identification document.
We also inform you that you have the right to lodge a complaint with the Spanish Data Protection Agency (www.agpd.es) and, beforehand, with the Data Protection Delegate at ANOVO at dpd.spain@anovo.es
This policy is updated, approved and published on 16 June 2018.