Privacy Policy

This Privacy Policy is made available to you to inform you in detail about how we process your personal data and protect your privacy and the information you provide to us.

Should any modifications be introduced to this Privacy Policy in the future, we will notify you through this portal or by other means, allowing you to be aware of the new privacy conditions adopted.

Below, we provide information in a question-and-answer format regarding the conditions under which our entity processes your personal data:‍

Who is responsible for processing your data?

- Entity: AMBAR PARTNERS TECH SERVICES, S.L., with Tax Identification Number (NIF):B88306147 (here in after, “Ambar”)‍

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

- NIF: B88306147

- Telephone: +34 91 992 08 74

- Email: lopd@ambarpartners.com‍

For what purpose do we process your personal data?

We process the personal data provided by you for the following purposes:

a) To manage the registration request, enabling users to access the Ambar House Portal and to provide the requested information for evaluation purposes.

b) Once the user accesses the Portal, we will process the data provided to determine whether the user is eligible to be accepted into the Ambar community and to work as a of the entity.

c) Upon acceptance of the user as a member of the Ambar Community, we will process their data for the correct management of the contractual relationship maintained with them.

d) To send commercial communications about our services (newsletters). These communications will be sent to members of the Ambar community, unless they express their objection by checking the appropriate box when providing their data or subsequently notifying us by any means.

In relation to the sending of such communications, based on the information provided, we may create commercial profiles to offer you services and news that best match your interests.

How long will we retain your data?

We will only retain your data for as long as necessary to fulfill the purpose for which it was collected, comply with legal obligations, and address any responsibilities that may arise from fulfilling the purpose for which the data was collected.

The data used for managing registration on our platform and evaluating the user to determine if they become part of the Ambar community will be retained for the following periods:

• If the user's request is denied and they do not become a member of the community, the data will be retained for a maximum period of two years to be considered for future evaluations. After this period, the data will be deleted.
• If the user is accepted into the Ambar community, their data will be retained for the duration of the contractual relationship. Once the relationship ends, the data may be retained for the period required by applicable legislation.

The user must keep the personal data provided to us updated, particularly those related to education and professional experience.

If, within two years, the user completes the registration form but does not provide the personal data necessary for evaluation by Ambar, their data will also be deleted.

The data used for sending commercial communications will be retained indefinitely until you notify us of your desire to delete them or to stop receiving such communications.

What is the legal basis for processing your data?

The processing of your data is necessary for the implementation of pre-contractual measures or for the execution of a contract to which the data subject is a party. Therefore, providing your data is mandatory; failure to do so would prevent us from processing your data for the purposes outlined in this policy.

The prospective offer of products and services to community members is based on the legitimate business interest of offering the services marketed by the entity.This legitimate interest is recognized by the applicable legal regulations(General Data Protection Regulation - GDPR), which expressly permit the processing of personal data on this legal basis for direct marketing purposes.Nevertheless, you are reminded that you have the right to object to the processing of your data, which you may do through any of the means provided in this clause. In any case, processing your data for this purpose is not mandatory, and refusal would only result in you not receiving our commercial communications.

The categories of data processed are those requested in each case in the form or contract through which you provide your data. 

Who are the recipients of your data?

The data will be communicated to the following entities:

a)     CompetentPublic Authorities, including judges and courts, in the cases provided for bylaw and for the purposes defined therein.

b)    Financial entities, through which the management of collections and payments is articulated.

c)     Clients, in cases where there is joint collaboration on a project or commercial opportunity.

Although this does not constitute a transfer of data, third-party companies acting as our service providers may access your information to perform the service. These processors access your data following our instructions, without being able to use them for any other purpose, and maintaining the utmost confidentiality based on a contract in which they commit to comply with the requirements of the applicable regulations on personal data protection.

Ambar may conduct international data transfers when, in cases of collaboration, contact details must be communicated to a client located outside the EuropeanEconomic Area. This communication constitutes an international data transfer, supported by Article 49.1(c) of the GDPR, as the transfer is necessary for the performance or execution of a contract, in the interest of the data subject, between the data controller and another natural or legal person. 

What are your rights concerning your data?

Any person has the right to obtain confirmation as to whether we are processing personal data concerning them or not. Data subjects have the right to access their personal data, request rectification of inaccurate data, or request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

Under the conditions provided for by the GDPR, data subjects may request the restriction of processing or the portability of their data, in which case we will only retain them for the exercise or defense of claims.

Under certain circumstances and for reasons related to their situation, data subjects may object to the processing of their data. If you have given your consent for any specific purpose, you have the right to withdraw it at any time, without affecting the lawfulness of the processing based on consent before its withdrawal. In such cases, we will stop processing your data or, where appropriate, cease processing them for that specific purpose, unless for compelling legitimate reasons or for the exercise or defense of possible claims.

Additionally, data protection regulations allow you to object to being subject to decisions based solely on the automated processing of your data when applicable.

The aforementioned rights are characterized by the following:

• Exercising your rights is free of charge, except in cases of manifestly unfounded or excessive requests (e.g., repetitive nature), in which case a fee proportional to the administrative costs incurred may be charged, or action may be refused.
• You may exercise your rights directly or through your legal or voluntary representative.
• Your request must be answered within one month, although, considering the complexity and number of requests, this period may be extended by an additional two months.
• We are obliged to inform you about the means to exercise these rights, which must be accessible, and we cannot deny your exercise of the right simply because you choose a different means. If the request is submitted electronically, the information will be provided by electronic means when possible, unless you request otherwise.
• If, for any reason, your request is not acted upon, we will inform you within one month of the reasons for this and your right to file a complaint with a Supervisory Authority.

To facilitate the exercise of these rights, we provide the following links to the request forms for each of them:

• Access Right Request Form
• Rectification Right Request Form
• Objection Right Request Form
• Deletion Right Request Form (Right to be Forgotten)
• Restriction of Processing Right Request Form
• Data Portability Right Request Form
• Right Not to Be Subject to Automated Individual Decision-Making Request Form

All the aforementioned rights can be exercised through the contact methods provided at the beginning of this clause.

In the event of any violation of your rights, especially when you have not obtained satisfaction in exercising them, you may file a complaint with the Spanish Data Protection Agency (contact details available at www.aepd.es) or another competent supervisory authority. You may also obtain more information about your rights by contacting these institutions

How do we protect your personal data?

We are committed to protecting the personal data we process. We employ reasonably reliable and effective physical, organizational, and technological measures, controls, and procedures to preserve the integrity and security of your data and ensure its privacy.

Additionally, all personnel with access to personal data have been trained and are aware of their obligations regarding the processing of your personal data.

In contracts with our suppliers, we include clauses requiring them to maintain the duty of confidentiality concerning the personal data accessed under the assignment, and to implement the necessary technical and organizational security measures to ensure the confidentiality, integrity, availability, and resilience of the systems and services processing personal data.

All these security measures are periodically reviewed to ensure their adequacy and effectiveness.

However, absolute security cannot be guaranteed, and no security system is impenetrable. Therefore, if any information under our control is compromised due to a security breach, we will take appropriate measures to investigate the incident, notify the Supervisory Authority, and, where applicable, inform those users who may have been affected so that they can take appropriate measures.

What is your responsibility as the data subject?

When providing us with your personal data, you guarantee that you are over 14 years of age and that the data provided is true, accurate, complete, and up-to-date.

You are responsible for the accuracy of the data provided and must keep it updated so that it corresponds to your actual situation, being responsible for any false or inaccurate data you may provide and for any direct or indirect damages that may arise.

If you provide data of third parties, you assume the responsibility of informing them in advance of everything provided in Article 14 of the General Data Protection Regulation under the conditions established in that provision.

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