Privacy Policy

1. What does it consist of?

The aim of this Privacy Policy is to explain to the interested party, in clear, simple terms and in a concise, transparent and intelligible way how MÓVIL ACCESS S.L., (hereinafter ZINKLAR) manage your personal data, which may be obtained within the framework of the provision of a service, request information, answer your questions, maintain our business relationship, perform direct marketing of our services, a selection process,  receipt of a service provided by you or if we manage them when you visit our website, personal information that is used exclusively for the purposes established in the present policy, guaranteeing the safeguard of your rights, confidentiality and security of the information, all in accordance with the legal obligations in force with regard to the protection of personal data and, especially, with compliance of the obligation for transparency according to the General Data Protection Regulation 2016/679 (hereinafter “GDPR”).

In the case that you are not satisfied with some aspect of the present policy, we inform you that it is possible you have legal rights, which have been described in the present policy.

2. Who is responsible for the processing of your personal data (controller)?

MÓVIL ACCESS S.L. is responsible for the processing of the personal data. The definition of responsible for the processing of personal data (“Controller”) according to the GDPR is as follows:

“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

MÓVIL ACCESS S.L.

TAX ID No.: B-63884282

Address: Ronda General Mitre, 126, 1º 3ª (08021). Barcelona.

Telephone number: +34 931 222 484

Commercial Registry of Barcelona: Volume 37.661, Page 50, Sheet number B-307.719.

Website: https://zinklar.com/

If you have any questions, comment or suggestion about how we use personal information, you can send an email to the following email address: [email protected].

3. What kind of personal information do we collect?

ZINKLAR may collect the following personal information.

Clients’ personal data

The data that we collect is contact information or in relation to the contact persons of your organization (name, telephone number or e-mail address) to guarantee an adequate range of services. What is more, we conserve information on your interaction with us and that we use to ensure that we send you the pertinent and appropriate marketing communications. In the same way, we may conserve the additional financial and tax information such as when you interact with our financial and debt collecting teams. If, for any reason, we require any other personal data, we will inform you.

Personal data of users that visit our Website

We collect the following personal information of ZINKLAR website users through the corresponding forms: name, e-mail address, postal address and telephone number when the user visits the website, registers, contacts ZINKLAR or participates in studies or surveys of ZINKLAR. Additionally, we collect very specific data which we use to improve your browsing experience, as well as to help us with the management of our services. Among it can be found information on how to use the website, the frequency with which it is accessed, the hours with greatest traffic, the type of browser, the Internet Protocol (IP) of the device you are using, the place from which it is visited, the language in which the website is consulted.

Personal data of our suppliers

We specifically collect a minimum of information on our suppliers, such as contact data of those responsible within your organization in order to be able to communicate, such as names, telephone numbers and e-mail. Moreover, it is necessary to collect the bank data in order to be able to pay for the services provided, in your favour, always in agreement with the contract signed.

The personal data of candidates in selection processes

Depending on the cases and on the applicable legislation, we may collect information pertinent to your work application and Curriculum Vitae indicated below in order to be able to offer you work opportunities that adapt to your professional interests and professional profile: name, age, contact information, professional path, training, legal status of foreigners, financial information in the cases in which we must verify your financial record and social security number, what is more, you may opt to share other information of interest with us. Where applicable, and in accordance with the legislation and local requirements, we may also collect information relating to your health or to aspects relating to diversity. What is more, it is probable that we will obtain additional personal information as our relationship progresses.

4. How do we obtain your personal data?

ZINKLAR may obtain your personal data as follows.

Clients’ personal data

ZINKLAR may obtain personal data in the following way:

  • We receive it directly from the Client:
    • When the client contacts us by telephone and/or e-mail.
    • When ZINKLAR contacts the Client by telephone, e-mail and/or promotional activities.
  • Automatic collection
    • Automatic collection of client data when they access the website
  • Received from other sources: According to the legal regulations, it is possible to request more information on the client, in general, from other sources, through due diligence or other market information mechanisms, among them:
    • Market studies from third parties and through the analysis of online and offline resources (that we may carry out ourselves or entrust to other organisations we may hire).
    • Lists of delegates in corresponding events.
    • Social networks like Twitter, Facebook, LinkedIn, among others. The information we collect through social networks sometimes includes personal information online is available and the public. We always make sure that all the information we use is attributed to its source correctly or made anonymous. It is likely that these social networks have their own privacy policies, through which will explain how they use and share your personal information. We recommend carefully review the privacy policies before using these social networks to be sure that you are happy with how your personal information is collected and shared.

Personal data on Users that visit our website

ZINKLAR collects the personal data on Users that visit our website, automatically through cookies according to the specific configuration of the user’s browser. If you wish to receive more information on the cookies, please look at the Policy on Cookies of ZINKLAR.

Personal data on suppliers

ZINKLAR will only collect the suppliers’ personal data during the contractual relationship or collaboration existing between them.

Personal data of candidates in selection processes

ZINKLAR may obtain the data in the following way:

  • We receive it directly from the candidate:
    • When the candidate leaves a physical copy of his/her Curriculum Vitae in our offices, at an event for the selection of personnel or a job fair.
    • When the candidate sends his / her Curriculum Vitae by e-mail or in an interview.
    • When the candidate introduces his/her data in the website or through a form, as part of the registration process.
    • When the candidate applies to a position through a website of employment offers that redirects him/her to ZINKLAR website.
    • When the candidate registers or applies to a competition on social networks (Twitter, Facebook, etc.).
  • Automatic collection: Automatic collection of the candidate’s data when s/he accesses the website.
  • Received from other sources: In accordance with the legal regulations, we may request more information on the candidate from other sources, in general, through due diligence or other market information mechanisms, among them:
    • The contact persons with regard to references may give of personal information on the candidate.
    • Our clients provide us with personal information on a candidate.
    • When we carry out searches for possible candidates in external sources, such as LinkedIn and/or other job portals.
    • Twitter and Facebook provide us with your personal information when you click on “Like” on our website or when you follow us.
    • If our profile reaches us through a supplier, it is possible that they inform us of your personal data.
5. For what purpose do we process your personal data?

ZINKLAR will process your personal data for the following purposes.

Personal data of the client

ZINKLAR will process their clients’ personal data in order to manage and guarantee the adequate fulfilment of the agreements and/or contracts signed between both parties, as well as to personalise our services to their needs.

  • Provision of Customised Services:
    • Store your data and update them, when necessary, in our database, in order to contact you in relation to the provision of our services. These are basically limited to a platform to design market research projects through questionnaires, instantly launching them to a wide range of consumer-representative targets (“Targets”), who receive and answer to questionnaires through their mobile phone, thus obtaining real-time results. Questionnaires are directly designed by the User who, if desired, shall request the assistance by a support team made available by MOVIL ACCESS (such support may be subject to additional costs). Targets who respond to surveys are anonymous subjects and, therefore, we do not process their personal data, they have been previously selected for such purpose, and are part of an exclusive panel of consumers from all types of sources, which ownership and management belongs to an entity specialised in the sector, with which MOVIL ACCESS has entered into a partnership and confidentiality agreement.
    • Manage records of our conversations and meetings, to be able to provide you with specific customised services.
    • Elaborate customer satisfaction surveys.
    • Manage your data to carry out marketing campaigns.
  • Marketing Activities:
    • Market research and commercial prospection, statistical studies and market trends, in order to offer products and services that may be of interest.
    • Process orders, requests or any type of request that is made by the user through any of the contact forms that are made available to him.
    • Send the newsletter of ZINKLAR.
    • Keep you informed, about our latest services, offers, opportunities, etc.
    • The channels that we usually use to send advertising commercial communications, but only if you give us your consent, are the following: email, postal mail, telephone, fax, SMS, MMS, social communities or any other electronic means or physical, present or future, that enables commercial communications.
    • Commercial communications will be made by the responsible ZINKLAR and related to its products and services, or its collaborators or suppliers with whom it has reached a promotion agreement. In the present case, third parties will never have access to personal data.
  • For the exercise or defence of a right in legal proceedings
    • In exceptional cases, we will use your personal data for the exercise or defence of a right in legal proceedings.

Personal data of Users that visit our Website

ZINKLAR will process the personal data of the Users of our website in order to improve their browsing experience on our website; for example, we analyze their latest search criteria to help us offer them the job offers or the candidates that we believe may be of their interest, or to help us in managing our services.

For more information on Cookies, including the way in which we use them and the options you have available, click on our Policy on Cookies.

Personal data of the suppliers

ZINKLAR will process personal data of their suppliers in order to manage and guarantee the adequate compliance with the agreements and/or contracts signed between both parties:

  • To store their data and update it when necessary in our database, so that we may get in touch with our suppliers in relation to our contracts.
  • To request their assistance or their services.
  • To comply with specific legal obligations.
  • To help us to direct suitable marketing campaigns.
  • In exceptional cases, for the exercise or defence of a right in legal proceedings.

Personal data of candidates in a selection process

Below we indicate different ways in which we may use and process your personal data in order to manage personalized services for the selection of personnel, where applicable and according to the legal requirements:

  • To collect the candidate’s data through you and from other sources, such as professional networks like LinkedIn.
  • To store their data and update them when necessary in our data base, so that we may get in touch with the candidate with regard to a personnel selection process.
  • To evaluate their data with regard to the professional offers that we consider adjust to their professional profile.
  • To verify the data provided by the candidate, using third party resources such as psychometric evaluations or aptitude tests, or to request information such as references, qualifications and possible criminal sentences, as appropriate and according to legal requirements.
  • If our candidate or prospective employee of ZINKLAR designated contact person for purposes of reference, we will contact you to request them.
  • To comply with our legal obligations.
6. Which recipients may we share of your personal data?

The personal data of the interested party may be share to the following recipients when applicable and in accordance with the legislation in force:

  • Public Administrations and Bodies when tax, labor, social security or any other applicable legislation requires it.
  • Companies in charge of data processing (“Processor”), such as suppliers that provide services to ZINKLAR as external consultants and professional advisors, lawyers, auditors, accountants and computer specialists, when they are appropriate and according to the legislation.
  • International data transfers may also take place of the previous actions for which ZINKLAR will use the Contractual Clause of the kind adapted by the European Commission and the EU-USA Privacy Shield as a guarantee of those transfers carried out to countries that do not have an adequacy decision from the European Commission. In any case, the third parties with whom certain data of a personal character is shared will have previously confirmed the adoption of technical and organisational measures that are adequate for the correct protection of them.
  • Under no circumstances ZINKLAR does not sell data to third parties.
7. For how long will we keep the personal data?

ZINKLAR will keep the personal data for the period of time that it were reasonably necessary bearing in mind the services we provide and the time for which you need it, the need to respond to questions that are posed or resolve problems, carry out improvements and comply with the requisites for storing information that the applicable legislation requires (for example, on request from a tax authority or in relation to possible law suits). This means that your personal data may be conserved for a reasonable period of time including after the interested party had stopped receiving the services of ZINKLAR or had stopped using the Website. Following this period, the personal data will be blocked from all ZINKLAR systems or we will remove them unless we believe in good faith that the legislation requires us to conserve them.

8. What gives us the legitimacy to process personal data?

ZINKLAR has the following legitimate bases for being able to process personal data.

Execution of the contract and contractual relationship

The legal basis for the processing of personal data of the interested party that is collected, is to enter into or comply with the execution of a contract, in order to comply with the obligations we assume on providing a service to you, or in order to take measures that you request from us to enter into a contract with us, it will be necessary for us to process your personal data. In this way, the interested party is obliged to provide the data that is necessary for its execution. In the case that the data were not provided, it will not be possible to carry out the service.

Legal obligations

Compliance of a legal obligation given that we are subject to certain legal requirements that may require from us that we process your personal data. The possibility also exists that we are obliged, by law, to divulge your personal data to a regulatory body or the police authorities.

Legitimate interest

In accordance with article 6, section 1, letter f), of the GDPR it is authorized to process your data when it is necessary to satisfy the legitimate interests pursued by ZINKLAR or by a third party, as long as over said interests the interests or rights and liberties of the interested party do not prevail that require the protection of personal data.

According to the above, ZINKLAR, or a third party, will have the need to process your personal data for our legitimate interest or the legitimate interest of a third party, providing that we have made it clear that said interest is not cancelled by your rights and liberties, including your right for your personal data to be protected. Our legitimate interest includes responding to requests from you or from a third party, to optimize the experience and satisfaction of the clients and users of our website, offer them information on our services and guarantee that our activities are carried out in an adequate way.

Consent

Consent in specific circumstances; it is possible that we will request your consent to process your personal data in a specific way. According to article 4, section 11, of the GDPR, consent is any expression of free, specific, informed and unequivocal will by which the interested party accepts, either through a declaration or clear affirmative action, the processing of personal data that concerns them, that is:

  • You must give us your consent freely, without us being able to exercise any kind of pressure on you.
  • You ought to be aware of what you are consenting to, for which we will ensure that we send you sufficient information.
  • You must grant us your consent through positive and affirmative action: it is probable that we will include a box that must be ticked to comply with this requisite in a clear and unequivocal way. We will maintain a register of the consent that you have given in this way.

When we process your personal data with your consent, you have the right to withdraw your consent at any time. You may do this in accordance with the procedure indicated in the present policy.

9. How do we protect your personal data?

ZINKLAR informs you that they have adopted the technical and organisational measures necessary to maintain the required level of security and confidentiality with regard to personal data processed and, likewise, has put the necessary mechanisms in place to avoid, as far as possible, unauthorised access, improper use, removal, illicit modifications and loss of data.

10. What are your rights in relation to personal data?

In accordance with the GDPR you have a series of rights of a protective nature which are indicated below.

The right of access

You have the right to obtain confirmation on whether in ZINKLAR we are processing personal data relating to you, or not, as well as how to gain access to the personal data that ZINKLAR has of yours.

The right to rectification

You have the right to request that ZINKLAR rectifies the personal data when they are inaccurate or to complete them when they are incomplete.

The right to erasure

You may request us to remove the personal data when, among other motives, the data is no longer necessary for the purposes for which it was collected.

Right to restriction of processing

You have the right to request the limitation of the data processing, in which case we will only conserve them for the year or for claims advocacy.

The right to data portability

You have the right to receive the personal data in a structured format, for common use and machine readable, and to transfer them to another person in charge when the processing is based on consent or on a contract, and is carried out through an automated means.

Right to object

You may oppose the personal data being object of processing based on public or legitimate interest pursued by ZINKLAR, including profiling. In this case, ZINKLAR will no longer process the data, except for compelling legitimate grounds or to exercise or defend possible claims.
Automated individual decision-making

You have the right not to be the subject of a decision based solely on automated processing, including the profiling that gives rise to legal effects with respect to you or affects you significantly in a similar way.

Right to lodge a complaint

You have the right to make a claim before the Spanish Data Protection Agency. Web: https://www.agpd.es/

To exercise your rights and to receive a response within the deadlines established by current legislation on data protection, you can contact the email address [email protected] always attaching a copy of your ID or Residence Card.

To exercise your rights contact us and we will try to process your request without undue delay and, in any case, within one month without prejudice to the extensions that the legislation permits.

11. Quality of the data

The data provided by the user must be exact and truthful. In all cases, it is the user who has the obligation to inform to ZINKLAR of any modification in their data in order that they may keep them updated at all times.

12. Minors

The services and information available on the website are intended for persons over 18 years of age.

13. Update of the privacy policy

ZINKLAR may modify and update the present Privacy Policy at any moment without prior notice. Please check that you are aware of our Privacy Policy in order to be informed at all moments of the information contained therein.

Last update: 2 August 2018