Privacy Policy

WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?

Holder: AMBAR PARTNERS TECH SERVICES, SL.

Address: C/ Guzmán el Bueno 133 - BJ, 28003 Madrid, Spain

TAX ID (CIF): B88306147

Phone: +34 697 628 122

FOR WHAT PURPOSES WILL WE PROCESS YOUR PERSONAL DATA?

a) Managing the relationship with potential and existing clients, including invoicing and payment of services.

Additionally, client data will be processed to comply with regulations on Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF).

Providing data for these purposes is mandatory; otherwise, we will be unable to draft and send proposals to potential clients or fulfill contracts and requested services.

b) Managing the relationship with our partners and potential partners. Specifically, the partner’s personal data and any contact details they provide, including email addresses, will be processed to draft the relevant proposal and manage the collaboration with AMBAR, including rights, obligations, and benefits as a member of the community. These details may also be used to send related information. Additionally, partners’ data will be processed to comply with AML and CTF regulations.

Providing data for these purposes is mandatory; otherwise, the collaboration agreement cannot be drafted or fulfilled.

c) Managing relationships with suppliers, including invoicing and payments. Suppliers must provide their data; otherwise, contracts cannot be executed.

d) Handling requests for information, suggestions, and complaints, contacting the sender, responding to their inquiries, and following up. Providing data for this purpose is voluntary; however, failure to do so will prevent us from addressing requests, inquiries, or complaints.

e) Sending commercial communications about our events, activities, and services, including our newsletter.

If you are a client or partner, we will send these communications unless you opt out by checking the relevant box when providing your data or informing us later through any available means.

If you have not contracted our services or collaborated with us, we will not send commercial communications unless you expressly authorize us. Authorization is voluntary, and refusal will only mean you won’t receive offers or information about AMBAR’s events and activities.

Based on the information provided, we may create commercial profiles to offer you products and services aligned with your interests.

f) Managing event registration and attendance. Providing data for this purpose is voluntary, but failure to do so will prevent participation in the events.

g) Processing images of participants in events organized or attended by AMBAR, including interviews, award ceremonies, or similar events. These images may be shared via AMBAR’s website, social media, corporate magazines, or other communication channels to promote its activities and events.

Additionally, AMBAR may include partners’ and employees’ images, names, job titles, and brief professional profiles in corporate materials and on its website to promote the firm’s services and professionals.

Providing data for this purpose is voluntary, but failure to do so means the images cannot be processed for this use.

h) Managing job applications submitted through our online form to assess candidates’ suitability for job openings or potential collaborations with AMBAR. Providing data is voluntary, but failure to do so will prevent participation in selection processes.

i) Managing the collaboration with event speakers. Speakers are informed that their presentations will be recorded and shared via AMBAR’s website and social media. Additionally, photographs may be taken to promote the event on AMBAR’s platforms.

Providing data for these purposes is mandatory; otherwise, the collaboration agreement cannot be fulfilled.

j) If you become a friend or follower on social media, your data will be processed to keep you informed about our activities and promotions through these channels. Providing data for this purpose is voluntary, but failure to do so will prevent you from following us on social media.

The categories of data processed for this purpose are identification data.‍

WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR DATA?

• The legal basis for processing data of clients, partners, collaborators, and speakers (including recording their presentations) is the execution of the contractual relationship. For potential clients or partners, the basis is pre-contractual measures.
• Compliance with AML and CTF regulations is based on legal obligations imposed by Law 10/2010, of April 28, on the Prevention of Money Laundering and Terrorist Financing.
• The prospective offer of products and services to existing clients and partners is based on AMBAR’s legitimate business interest in promoting additional services and fostering loyalty. This is explicitly permitted by the General Data Protection Regulation (GDPR), which allows personal data processing for direct marketing purposes under this basis. However, you have the right to object to this processing at any time.
• The prospective offer of products and services to individuals who showed interest but did not become clients or partners is based on their explicit consent. This consent is revocable at any time, and revocation will only affect future communications.
• The legal basis for processing data to respond to information requests, inquiries, and complaints is the user’s consent, which can be withdrawn at any time. However, past data processing remains lawful.
• The legal basis for processing data to manage event registrations and attendance, as well as for image processing under section g), is consent. This consent can be revoked at any time without affecting previous processing.
• Incidental image capture during events, in accordance with Organic Law 1/82, is not considered an unlawful intrusion into privacy or personal image rights. Thus, capturing such images is based on public interest under Article 6.1(e) of the GDPR.
• AMBAR reserves the right to photograph and record all events it organizes, either alone or with third parties. If you wish to have your image and voice captured and used for promotional purposes, you must provide explicit consent. If you do not consent, you should avoid voluntarily appearing in the recordings and photographs.
• The legal basis for processing CVs submitted for job applications is the pre-contractual relationship.
• The legal basis for storing CVs after a selection process or when submitted spontaneously is the candidate’s consent, which can be revoked at any time.
• Data provided through social media will be processed based on user consent, which can be withdrawn at any time.

The categories of data processed depend on the specific form or contract used to submit them.

TO WHOM WILL WE DISCLOSE YOUR DATA?

The data will be disclosed to the following entities:

• Competent Public Administrations, including judges and courts, in cases provided for by law and for the purposes defined therein.
• Partner data will be disclosed to clients whose project they will be handling so that they are aware of the assigned lawyer and can contact them.
• Financial entities through which the management of collections and payments is processed.
• The personal data provided by the client may be disclosed to public authorities in order to comply with obligations imposed by applicable regulations, as well as to collaborating lawyers who need to be involved in the provision of the service. Likewise, the client’s data will be shared with financial institutions for the management of payments and collections.
• Images and recordings referenced in sections g) and i) of the section "For what purpose do we process your data?" may be published on the entity’s website, social media, corporate magazines, or any other similar communication medium owned by AMBAR, which implies a transfer of personal data.
• Although this is not considered a transfer of data, third-party companies acting as our suppliers may access your information to carry out the service. These suppliers access your data following our instructions, without being able to use it for any other purpose, maintaining strict confidentiality, and under a contract in which they commit to complying with the requirements of current personal data protection regulations.

AMBAR carries out international data transfers when the lawyer’s contact details must be communicated to a client located outside the European Economic Area so that they can be informed about the assigned lawyer and contact them for the development of the case. This communication constitutes an international data transfer, protected under Article 49.1(c) of the GDPR, as the transfer is necessary for the conclusion or execution of a contract, in the interest of the data subject, between the data controller and another natural or legal person.

We will not use your personal data for any purpose other than what is stated in this privacy policy.

HOW LONG WILL BE STORE YOUR DATA?

We only keep your data for the period necessary to fulfill the purpose for which they were collected, comply with legal obligations, and address any potential liabilities arising from the fulfillment of said purpose.

• Data for managing relationships with clients, suppliers, partners, and speakers, as well as for invoicing and payment collection, will be retained as long as the contract remains in effect. Once the relationship ends, data may be stored for the period required by applicable legislation and until any potential liabilities arising from the contract expire.
• Data required to comply with anti-money laundering and counter-terrorist financing regulations will be retained for 10 years.
• Data for sending commercial communications about our services, events, and activities will be stored indefinitely until you express your wish to delete them or to stop receiving such communications.
• Data of potential clients or partners who do not ultimately contract our services or collaborate with us and do not wish to receive commercial information will be deleted when it is confirmed that no contract will take place. If any potential liability arises from the preliminary relationship, data will be retained until it expires.
• Data used to respond to requests, inquiries, or complaints will be stored for as long as necessary to provide a final response. Subsequently, they will be kept as a record of communications for one year unless you request their deletion earlier.
• Data for managing registration and attendance at events organized or attended by AMBAR will be retained while the events last and afterward as long as there is any legal liability linked to the participation of attendees.
• Data provided or obtained for participation in a recruitment process or collaboration search will be retained until the process is concluded and then deleted unless the candidate is selected, in which case the data will be included in their employee or collaborator record. Candidates not selected who wish for their CVs to be kept for future processes must request it via email. In such cases, or when a CV is submitted spontaneously for future consideration, data will be stored for up to one year from the last update. You must keep your personal data updated, especially regarding education and professional experience.
• During recruitment processes, job portals may be used to search for candidates, including collaborators, who meet the desired professional profiles, in accordance with the privacy policies of these platforms. The personal data categories processed in such cases include identification data, personal characteristics, employment details, academic and professional data, and any other information published by the candidate on the job portal or included in their CV.
• Images (including recordings of speakers) referenced in sections g) and i) will be stored indefinitely or until consent is withdrawn or deletion is requested.
• Data provided via social media will be retained as long as you remain a friend or follower on the corresponding platform.

WILL YOU SEND ME COMMERCIAL COMMUNICATIONS AND PROMOTIONS?

AMBAR does not engage in SPAM practices and does not send unsolicited commercial emails unless previously requested or authorized by the user, except when such communications are based on legitimate interest as outlined in this Privacy Policy. Therefore, each form on the website provides the user with the option to give express consent to receive such information, independently of any commercial information specifically requested.

ARE MINORS ALLOWED TO USE AMBAR´S SERVICES?

Minors are not authorized to contract the acquisition of services offered by AMBAR. This possibility is restricted to individuals aged 18 and over.

HOW ARE PERSONAL DATA PROTECTED?

To safeguard the security of your personal data, we have adopted all necessary technical and organizational measures to ensure the security of data transmission, collection, storage, and disclosure. These measures prevent and react to risks such as alteration, loss, unauthorized access, or processing.

WHAT SIGHTS CAN YOU EXERCISE?

Under current legislation, as a data subject, you may:

• Request access to your personal data to determine if we are processing them and to access your personal data.
• Request rectification of any inaccurate data.
• Request the deletion of your data if they are no longer necessary for the stated purpose or if we no longer have the necessary legal basis to process them.
• Request the restriction of processing under certain circumstances, allowing us to temporarily suspend processing or retain data beyond the established period if you need them.
• Object to processing unless there are compelling legitimate grounds for the processing to prevail.
• Request data portability, receiving them in a structured, commonly used, and machine-readable format.

Additionally, you may file a complaint with the Spanish Data Protection Agency (www.aepd.es) or another competent supervisory authority if you believe your request has not been properly addressed.

HOW CAN YOU EXERCISE YOUR RIGHTS?

To facilitate the exercise of these rights, the following links provide access to request forms:

• Access request form
• Rectification request form
• Objection request form
• Deletion request form
• Restriction of processing request form
• Data portability request form
• Right to not be subject to automated decision-making request form

Forms can be sent by postal mail to the address indicated in this policy or by email to lopd@ambarpartners.com.

WHAT IS TE TIMEFRAME FOR RESPONDING TO RIGHTS REUQETS?

We will inform you of the actions taken in response to your request within one month. This period may be extended by two additional months for particularly complex requests, in which case you will be notified within the first month. If we do not process your request, we will inform you and provide reasons within one month.

CAN THE PRIVACY POLICY CHANGE?

AMBAR reserves the right to modify this policy to adapt it to legal or industry practice developments. Any changes will be announced on this page reasonably in advance of their implementation.

WHAT ARE YOUR RESPONSABILITIES AS A DATA OWNER?

By providing us with your personal data, the person doing so guarantees that the data provided is true, accurate, complete, and up-to-date.

For these purposes, the data subject is responsible for the accuracy of the data and must keep it properly updated so that it reflects their real situation. They are liable for any false or inaccurate data they may provide, as well as for any direct or indirect damages that may arise.

If you provide data about third parties, you assume the responsibility of informing them in advance of all the provisions set out in Article 14 of the General Data Protection Regulation (GDPR) under the conditions established therein.

HOW DID WE OBTAIN YOUR DATA?

In general, AMBAR obtains data directly from the data subjects. However, in some cases, AMBAR processes professional contact data obtained from the internet to contact individuals (clients and partners) and attempt to obtain their consent to send them commercial information about AMBAR (including details about the entity’s services, events, and activities).

Considering the above, this processing is based on the provisions of Article 6.1(f) of the GDPR (legitimate interest), as the following conditions are met:

a) The processing refers exclusively to the data necessary to locate the data subject in their professional capacity.

b) The purpose of the processing is to maintain relationships of any kind with the legal entity in which the data subject provides their services.

The same presumption applies to the processing of data related to sole proprietors and independent professionals, provided that such data is used exclusively in their professional capacity and not for establishing a relationship with them as private individuals.

In any case, data subjects may object to the processing of their data by contacting AMBAR at any of the addresses listed in this Privacy Policy. Since the entity is not required to carry out this processing, if an objection is raised, AMBAR will not contact the data subject for the stated purposes.

If the data subject gives their consent to receive commercial information from AMBAR, their data will be retained indefinitely until they request its deletion. If no consent is given, the data will be deleted.

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