Privacy Policy
In compliance with Regulation (EU) 2016/679 of 27 April 2016, (hereinafter “GDPR”, the Organic Law 3/2018 on Data Protection and guarantee of digital rights, as well as the rest of the applicable legal regulations, you are provided with the following information about our processing of your personal data on this website.
Personal data
(1) of the GDPR, “personal data” means “any information relating to an identified or identifiable natural person”; “and an identifiable natural person is any person whose identity can be established, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person”.
Responsible for data processing
LLORENTE & CUENCA MADRID, S.L. (“LLORENTE & CUENCA” or “the Company”) has its registered office at Calle Lagasca 88, 28001 Madrid, Spain and C.I.F. number B-82894122 is registered in the Mercantile Registry of Madrid, Volume 16.152, Folio 92, Section 8ª, Page M-273.715, 1st inscription.
Purposes of the processing of your personal data
In general, with your consent we will process your personal data for the following purpose(s):
- Send you our customized value-added content specific to you.
- Personalize our proposals based on the observation of your browsing habits.
- Manage your request for specialists to participate in an event or help you manage a challenge.
- Manage and respond to your requests for information, suggestions or comments to our content hosted on the web, as well as respond to any inquiry or suggestion made through the fields provided.
- To take into account your candidacy to hire you, when you register in the offer published in our job portal, as well as to keep, in case you specifically consent us, your data for future job calls.
- Management of the operation and maintenance of the website.
- Check that you are a shareholder of the company to send you information of interest and added value in this area. It will only be applicable to those shareholders who, after being informed of this fact and giving their consent, consider it appropriate by subscribing to this service on the website or form provided for this purpose.
Retention period of your data
The Company will process your personal data for the essential time, depending on each case.
- In connection with the delivery of our value-added content, we will process your data until three years have elapsed since your last interaction with us or until you indicate your wish to unsubscribe (whichever is sooner).
- In connection with your inquiries and complaints, we will retain your blocked data once we have answered or resolved the inquiry.
- We will retain your CV and related personal data for a period of two years from receipt, destroying those that are clearly not of interest for recruitment purposes.
After these periods have elapsed, we will retain your blocked data for the legally established periods and the statute of limitations for possible liability claims arising from the corresponding processing.
Data update
Please inform us immediately of any changes to your data so that the information contained in our files is always up to date and contains no errors. In this sense, we understand that the information and data you have provided us are accurate, current and truthful.
Legitimate bases for our processing of personal data
The Company processes your personal data for various purposes. Each processing of personal data must be based on a legitimate basis, among those provided for in the regulations. The Group companies use the following bases:
- Consent: You have given your unequivocal and specific consent to the processing of your personal data for a specific purpose (e.g. subscription to the sending of content).
- Legal obligation: The law requires them to be processed and sometimes transferred to certain institutions (e.g. State Security Forces and Corps).
- Legitimate interest of the Company, provided that its interests, rights or freedoms do not prevail over such interests.
A.- Consent
The Company sometimes collects your personal data with your prior and unequivocal consent. For example, when you request the sending of our contents to your email. For example, to manage your comments and respond to any queries or suggestions made through the form itself. Consequence of failure to provide data The data (and consents) that we request are necessary for the treatments and purposes indicated, so that the omission of any of them will prevent us from executing the aforementioned purpose. The acceptance of these treatments is absolutely voluntary and your refusal will not entail any negative consequence for you.
B.- Legal obligation
The Company is obliged in some cases, by virtue of different legal regulations (regardless of whether or not you give your consent), to process and/or transfer certain personal data to different entities.
C.- The Company’s Legitimate Interest
In addition to the above assumptions (legal obligation, consent), there are a number of reasons that allow us to use your personal data. This legal basis for processing is “legitimate interest”. Generally speaking, the legal basis of “legitimate interest” means that we may process your personal data if we have a real and legitimate interest in doing so and our processing does not prejudice your rights and interests (indeed, in many cases, as we will see, our interests and yours are aligned, i.e., they coincide in whole or in part).
Examples of our legitimate interests and the processing we conduct based on those interests:
We refer to personal data that you have provided to us directly, or that we have observed or collected in the course of our dealings or interaction with you.
The potential impact on you and your rights and interests has been carefully assessed by the company and, where deemed necessary, we have implemented specific protective measures to mitigate such impact on your person and interests. For example, we will store your IP address as a preventive measure and to protect our computer security on the website. For example, based on our legitimate interest in offering you new services, we may send you commercial communications related to services or content similar to those you have already requested. This legitimate interest is recognized in art. 21.2 of the Law of Services of the Information Society.
For example, our legitimate interest in ensuring that information of interest and value to LLYC shareholders is effectively forwarded to those individuals who hold such status, thereby mitigating the risk of identity theft.
Addressees
The Company will transfer your personal data to third parties in the following cases:
a.-Consent In cases where you give your consent to do so.
b.- Assignment due to legal obligation: In those cases in which the Company is obliged by law.
c.- Legitimate interest:
The data you provide will be included in a database to which the following subsidiaries of the LLORENTE & CUENCA Group in Spain have access, deciding within the group the most appropriate company to attend you: LLORENTE & CUENCA, S.A.; LLYC MADRID, S.L.; LLYC BARCELONA, S.L.; LLYC PORTUGAL, S.L.; APACHE MEDIA GROUP, S..L.; CHINA PARTNERS, S.L.: LLYC BRUSSELS, S.L.; LLYC AMERICA, S.L.LLYC ARGENTINA, LLYC BRASIL, LLYC CHILE, LLYC COLOMBIA, LLYC ECUADOR; FACTOR C; LLYC DOMINICANA; LLYC MEXICO; LLYC LIMA; LLYC PERU; LLYC PANAMA; LL&C USA; LL&C MIAMI; IDEAS & RESULTADOS; SERVICIOS DE GESTIÓN LLYC ECUADOR; SERVICIOS DE GESTIÓN LLYC DE CV.
Provision of third-party services with access to personal data
In some cases we have external companies or suppliers, who access your personal data, to collaborate with us by providing specific services, for example, computer support or hosting of information in the “cloud”, backup in the cloud. With all these companies, the Company signs the corresponding confidentiality and personal data protection contract to ensure that the use of the data to which we give them access for the provision of the service is carried out in accordance with current legislation on data protection.
Your data may be transferred to third countries outside the EU, such as the United States of America, as a result of having external service providers. The transfer is covered by the selected providers’ adherence to the Data Privacy Framework signed between the European Union and the United States (Article 45 of the GDPR – Adequacy Decision). For the remaining providers that have not subscribed to this framework, it is covered by the adoption of updated standard contractual clauses (2021) approved by the European Commission (article 46.2.c of the GDPR).
Comment moderation
User comments to the content published on this website will be public. Llorente y Cuenca reserves the right to moderate, suspend or remove any comments that violate the respect to the dignity of the person, that are discriminatory, xenophobic, racist, pornographic, that attempt against youth or childhood, socially accepted values, or that, to the best of its knowledge and belief, are not appropriate for their disclosure in a web of these characteristics. In any case, LLORENTE Y CUENCA will not be responsible for the opinions expressed by the users through these comments or any other participation tool.
Security
LLORENTE & CUENCA takes all necessary technical and organizational security measures to protect your personal data against loss or misuse. For example, your data is stored in a secure operating environment with no public access. Your personal data is encrypted, using Secure Socket Layer (SSL) technology during transmission. This means that an approved encryption procedure is used for communication between your computer and LLORENTE & CUENCA’s servers.
If you wish to contact LLORENTE & CUENCA by e-mail, please note that we cannot guarantee the confidentiality of the information sent. The contents of the e-mail messages may be read by third parties. Therefore, we recommend you to send us confidential information only by ordinary mail.
Your rights in connection with our processing of your personal data
In relation to your data processed by the Company, you have: In any case the following rights:
- Transparency about how we use your personal data (right to be informed). Right that we satisfy, for example, through this legal text.
- Right to request a copy of the information we hold about you, which will be provided to you within one month (right of access).
- The right to update or change information we have about you if it is incorrect (right to rectification).
- The right to request that we stop using your information while a complaint filed by you is being resolved, among other things (the right to have the processing limited).
In addition, when we process your personal data based on your consent or on our contractual relationship with you:
- The right to request that we remove your personal data from our records (right of removal or “right to be forgotten”).
- The right to obtain and reuse your personal data for your own purposes (right to data portability).
- The right to revoke at any time your previously given consent to any of our processing of your personal data.
Or, when we process your personal data based on our legitimate corporate interests:
- The right to object to the processing of your personal data based on our legitimate interests by invoking circumstances based on your personal situation (right to object).
Form of exercise
You may exercise your applicable rights in each case by notifying the Company by any of the following means:
- By writing to the following e-mail address [email protected], accompanied by a scan of your ID card.
- You can also send us your request by letter with a copy of your ID card and making visible reference to “LOPD” on the envelope to:
LLORENTE & CUENCA MADRID, S.L., A/A of Legal Department. Calle Lagasca 88, 3rd floor. 28001 Madrid, Spain You can access the information necessary to exercise all the above mentioned rights (with detailed explanations and forms) on this website provided by the regulatory body: the Spanish Data Protection Agency (www.aepd.es). You also have the right to file a complaint before the Spanish Data Protection Agency (or AEPD) especially in the case that you consider that you have not obtained satisfaction in the exercise of your rights.
Changes in the data protection declaration
LLORENTE & CUENCA reserves the right to modify its data protection statement. LLORENTE Y CUENCA will notify or announce the new content and the dates in which a revision of the present terms will take place, for the information of its users.
Detailed information on the processing of your personal data by AIgent
Data controller
LLORENTE & CUENCA MADRID, S.L., Calle Lagasca 88, 28001 Madrid, Spain.
Contact address for privacy-related matters: [email protected].
Purposes for processing personal data
Your personal data will be processed for the following purposes:
- Respond to your inquiries about our services through the chatbot created for this purpose.
Our chatbot has been trained using information publicly available from our company, as well as the knowledge and expertise of our professionals. When you ask a question, the chatbot analyzes it and generates a response. This has been designed to ensure that the analysis and response will not have any significant impact on your personal data.
Any commercial interaction will be managed and supervised by a qualified member of our team.
While AIGENT is trained and supervised by LLYC, we can’t guarantee error-free operation due to the inherent nature of mistakes in large language models (LLMs) used in AI.
Legal basis for processing personal data
LLYC processes your personal data on the following legal basis:
a) Consent
LYC will collect your personal data based on your explicit consent, provided when submitting an inquiry to the chatbot.
Third-party service providers with access to personal data
We enlist external companies or service providers with access to your personal data to ensure the chatbot’s proper functioning and security.
All third parties are required to follow confidentiality and data protection agreements to make sure that they use your personal data in accordance with the relevant data protection laws. If you want to know more about the third-party services that involve accessing personal data, please get in touch using the contact address provided in this document.
Data sharing and international transfers
The data collected through this chatbot is stored on servers located within the European Union. Some of our service providers may transfer data internationally, and these transfers are covered by adequacy decisions, such as the EU-U.S. Data Privacy Framework, or by standard contractual clauses.
Data retention period
Personal data will be retained for as long as necessary to fulfill the outlined purposes:
- Personal data and information of users who become clients will be stored in compliance with the relevant legal requirements. For example, tax obligations expire after four (4) years, as stated in Article 66 of Law 58/2003.
The Code of Commerce mandates a six (6) year retention period for business-related documents and records.
Longer retention periods may be necessary in specific cases (e.g., deductions of negative taxable bases or requirements to substantiate funded projects). - For all other cases, your personal data will be blocked after we have responded to your inquiry and retained only for the period necessary to address any potential liabilities related to the processing of your data.
Updating personal data
We kindly request that you notify us promptly of any changes to your personal data so that the information we process is accurate and up to date. By providing us with your personal data, you confirm the information is accurate, current, and truthful.
Your rights regarding the processing of your personal data
You have the following rights concerning the data processed by LLYC:
- Right to be informed about how your personal data is used, which we satisfy through this legal notice.
- Right of access to request a copy of the personal data we hold about you, which will be provided within one month.
- Right to rectification to update or correct any inaccurate personal data we hold.
- Right to restriction to request that we temporarily cease processing your data in specific circumstances, such as while a complaint is being investigated.
- Right to erasure (also known as the “right to be forgotten”), allowing you to request the deletion of your personal data from our records.
- Right to data portability to obtain and reuse your personal data for your own purposes.
- Right to object to the processing of your personal data, particularly when based on legitimate interests or for direct marketing purposes.
- Right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
- Right to be informed of any automated decision-making processes, including profiling.
How to exercise your rights
You may exercise your rights by notifying LLYC through one of the following methods:
a. Email a scanned copy of your ID to [email protected].
b. Sending a letter, with “DATA PROTECTION” clearly indicated on the envelope, to LLORENTE & CUENCA MADRID, S.L., Calle Lagasca 88, 28001 Madrid, Spain.You may access further information about exercising your rights, along with detailed explanations and relevant forms, on the Spanish Data Protection Agency (AEPD) website.
You also have the right to complain to the AEPD if you believe that your rights have not been adequately addressed.
Last revision: October 2023