COLOMER LEATHER GROUP, S.L. (“CLG” or the “Group”).
The processing and evaluation of reports filed through the Ethical Channel, in order to carry out the necessary investigations in connection with the reported conduct.
Compliance with applicable requirements set out in the applicable laws and regulations to which CLG is subject.
(a) Legitimate business interests.
(b) Compliance with applicable legal or regulatory obligations.
Other entities belonging to the Group, to the extent necessary to process reports and carry out the necessary investigations.
Third party service providers.
Law enforcement agencies, courts, regulatory bodies, government authorities or other third parties with full authority.
You have the right to request access, rectification or deletion of personal data, as well as the restriction of further processing and portability.
The above rights may be exercised by sending an application together with a copy of your national identity card or equivalent identification document by e-mail to [email protected]
Please refer to the following email address for more information: [email protected]
In the context of receiving and processing of your report, COLOMER LEATHER GROUP, S.L. (“CLG”) will collect certain information about you that is considered “personal data”, within data protection framework. Specifically, personal data provided through this Ethical Channel will be included in a database in respect of which CLG, with registered office at Calle Figueres (PLA ST dels Pradals), 12, piso 2, Desp 8, 08500 Vic and email address [email protected] is considered responsible for data processor.
Please note that personal data collected through this Ethical Channel, as well as any subsequent communication between you and CLG in connection with the relevant report, is essential to determine the validity of that report also to ensure proper investigation of the reported conduct.
CLG will collect and further process the personal data you provide through the Ethical Channel for the following purposes, including its legitimate basis:
(i) To process and assess the report and any subsequent related communication submitted through the Ethical Channel, as well as to carry out the investigations as CLG deems appropriate in connection with the reported conduct, taking into consideration CLG’s legitimate business interests. In order to be able to rely on this legitimate basis for the processing of personal data, CLG has carried out a prior weighting analysis to ensure that your fundamental rights and freedoms do not prevail over your own interest. Additional information on this analysis is available on request.
(ii) To ensure an optimal compliance level with the applicable requirements set out by the relevant laws and regulations to which CLG is subject, including employment, social security, tax and criminal law, as well as to facilitate the cooperation with regulatory agencies and law enforcement agencies, where necessary, in order to respond to requests received from authorities and public bodies that have decision-making power.
For the achievement of the same purposes described above, CLG may not disclose or otherwise allow access to personal data, as the case may be, to other parties, including but not limited to the following:
(i) Other entities belonging to CLG’s companies when necessary and only to the extent necessary to determine the validity of the report, to request information from certain internal functions, if necessary, and, on the other hand, to support the investigation of possible misconduct, including communication of its outcome to interested parties.
(ii) Third party providers of services related to the advisory, legal and consulting sectors, such as external consultants, law firms, auditors, forensic experts, information technology managers, translators, investigators and, if necessary, authorities that provide certain services and other commercial activities to CLG, and access to personal data will be provided to the extent necessary to carry out the data processing operations that provide these types of services or activities as described in this notice.
(iii) Law enforcement agencies, courts, regulatory agencies, governmental authorities or other third parties with full authority, as CLG deems necessary for compliance with applicable requirements set out by relevant laws and regulations, or otherwise to protect its own rights or the rights of a third party.
Please note that some of the information previously disclosed to certain third parties, or their access to such information, will involve the international transfer of your personal data outside the European Union. However, CLG should provide adequate safeguards to ensure that your personal data is treated with the same level of protection as it would have been afforded in its own jurisdiction, such as the standard contractual clauses approved by the European Commission. You can access these documents or obtain a copy of the relevant decisions by clicking on the following links: 2004/915/EC (Standard contractual clauses for the transfer of personal data from the Community to third countries (transfer between processors) and 2010/87/EU (Standard contractual clauses for the transfer of personal data to processors established in third countries), respectively, or by contacting us via the e-mail address provided at the end of this document.
CLG shall store and process your personal data on servers located in Spain and maintain them for the duration of the investigation, and for at least two months following i) the conclusion of an investigation or ii) as a result of a report for which CLG determines a lack of sufficient evidence. Please note that such retention periods will apply alongside any other relevant limitation periods imposed by the legally required retention periods that CLG is expected to comply with under applicable law.
You are entitled to receive confirmation from CLG, recognizing whether or not your personal data is being processed and, if so, to request access to the personal data, as well as certain information on the processing thereof (the purposes, categories and recipients of the personal data being processed, etc.) (right of access). You also have the right to request the rectification of inaccurate personal data (right of rectification) and their deletion when, among other reasons, they are no longer necessary for the purposes for which they were collected (right to be forgotten). In certain cases, for example, if the data subject has doubts as to the accuracy of the personal data while they are being verified, he or she may request a restriction on the processing of such data, which may only be processed in order to lodge a complaint or oppose it (right to limitation of processing). Finally, you may also exercise the right to data portability, i.e. to receive personal data in a structured, commonly used and electronically readable format, as well as the right to transmit them to another data controller without being prevented by the data controller to whom you have provided them, when you are legally authorized for such purposes (right to data portability).
In addition to the rights stated above, you have the right to object to the processing of your personal data at any time, for reasons related to your particular situation, when the processing is based on legitimate interest.
You may exercise your rights by sending a request together with a copy of your national identity card or equivalent identification document by e-mail to [email protected]
You also have the right to file a claim with the data protection authority at local level, especially if you believe that the exercise of your rights has not been resolved to your satisfaction.
CLG is committed to protecting your personal data as described in this notice and prescribes applicable law. If you have any questions or intend to request additional information regarding how to exercise your rights, please do not hesitate to contact us at [email protected]