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Privacy and Cookies Policy

1. INFORMATION ON DATA PROTECTION

By means of this Privacy Policy (hereinafter, the Privacy Policy), ASIGNO SERVICIOS INTEGRALES DE RECUPERACIÓN DE CRÉDITO, S.L. (hereinafter, ASIGNO), with registered address at Paseo de la Castellana, no. 23, 28046 - Madrid and Taxpayer Identification No. B-85736023, registered with the Commercial Registry of Madrid, in Volume 26.934, Page 64, Section 8, Sheet M-485375, Entry 1, states that it is the titleholder and administrator of the domain name www.asigno.es (the Website, o Webpage).

In this Privacy Policy, we explain who is responsible for the processing of your data, why your personal data will be processed, the different legitimate rights and legal basis for the processing, the possible recipients of your data, why it is collected and your rights to control the data you provide us at all times. If you have any questions regarding the processing of your personal data, you can contact us at the following e-mail address: privacidad@grupolener.es.

We inform you that in order to navigate on our Website, use our computer applications and/or communicate electronically with us, your personal data will be collected and processed as a user of our Website (hereinafter, a User), For example, personal data is collected from Users to receive information on the different legal services described on our Website. The processing of this data is governed by this Privacy Policy.

Minors cannot use the services available through our Website without the prior authorization of their parents, guardians or legal representatives, who will be solely responsible for all the acts performed using this Website by the minor under their care.

ASIGNO undertakes to keep your personal data protected and ensure that it is not used for any unauthorised purpose..

ASIGNO informs you that it assumes responsibility for complying with current national and European legislation on data protection, in accordance with REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter the General Data Protection Regulation), and in accordance with the Organic Law 3/2018 of December 5, 2018, on the Protection of Personal Data and guarantee of digital rights (hereinafter LOPD ) and will proceed to process your data in a transparent, lawful, fair and proportionate manner.

2. WHO IS REPONSIBLE FOR PROCESSING YOUR DATA?

According to the European Regulation definition, a data controller is “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”.

Your data controller is ASIGNO SERVICIOS INTEGRALES DE RECUPERACIÓN DE CRÉDITO, S.L.

As a User you warrant to ASIGNO, and third parties the quality of the information you provide us at any time you decide to send us information to request our legal services, which means that the personal data you send us and the information provided must be real, truthful and fully updated and that you guarantee that such data and information belongs to the User User and not to other third parties, you are liable to ASIGNO for the accuracy and quality of the personal data provided and that the provision of false or outdated data is prohibited. Please inform us as soon as possible of any changes or corrections to your personal data that may occur, by sending an e-mail to the following address: privacidad@grupolener.es

3. WHY IS YOUR DATA PROCESSED?

ASIGNO informs you that we process the data provided by Users, for example, through their electronic communications with us, in order to:

  • Facilitate the management of information that may be requested by Users through the contact facilities displayed on our Website in order to manage the queries raised, as well as to allow the correct functioning of the Website. Your data may also be processed if you are interested in the legal, economic and debt recovery services that may be requested through our Website.
  • Provide the contracted legal, economic and debt recovery advisory services, as well as to correctly manage the contractual relationship, including the management of the access of registered clients to their files; in the event personal data is requested for the services made available through the Website, Users will be duly informed of the conditions and purpose of the data processing.
  • Keep clients informed of the services provided and any developments relating to them.
  • Keep clients timely informed with information on services and legislative developments of interest, news, promotional and marketing circulars, information on events organized by the LENER GROUP by either electronic or non-electronic communications.
  • ASIGNO has also implemented a section devoted to staff selection on its Website, specifically at url: https://joinus.lener.es/ This section provides an opportunity for all those interested that consider that their professional goals are in line with present and future objectives and candidatures of ASIGNO, or any company that belongs to the Lener Group. In particular, ASIGNO informs users and candidates interested in sending us their curriculum vitae ( CV ), by electronic means, as the credit controller, that it shall process the data provided in the CV and the personal data contained therein in order to manage the required staff selection process and candidatures in present and past selection processes that are active in our organization and coincide with your profile, as well as to manage contact with data subjects as job candidates. Your refusal to provide us with your CV and minimum contact details will mean that you cannot take part in present or future selection processes at our organization. ASIGNO thanks you for your interest in joining our team and, with your consent, will keep your CV for the notified term, for the purpose of offering you positions in line with your professional profile, the legal basis of processing the data being your request to take part in a present or future selection process and the legitimate interest being your prior consent, which may be revoked at any time.

4. WHAT IS THE LEGITIMATE BASIS FOR PROCESSING YOUR DATA?

ASIGNO informs you that the legitimate basis for processing your data will vary according to the purpose for which we have gathered it:

  1. If the purpose is to manage an enquiry raised in relation to our legal and debt recovery services, the legal basis of processing of your data will be the legitimate interest held by ASIGNO in complying with the request for information through our Website by the User.
  2. If the purpose is to provide legal-financial or debt recovery advisory services or to suitably comply with contractual relations management and keep you timely informed of the legal services provided or any developments therein, the legal basis for the processing will be our legitimate interest and the contractual relationship to provide the legal or financial advisory services you have requested, even if they are free of charge..
  3. In the event the purpose is to keep our client timely informed with information on services and legislative developments of interest, news, promotional and marketing circulars or information on events organized by ASIGNO, the legitimate basis for the processing will be your consent. In such case, you will be entitled to withdraw your consent at any time, however it will not affect the legal processing based on your consent provided before said withdrawal. In section 8 (eight) of this Privacy Policy, you can find a simple mechanism to revoke or withdraw your consent for the purposes of this point iii.
  4. In the specific case in which the purpose lies in the management of a staff selection process, the legal basis for processing shall be the candidate's consent to inclusion in the job candidate database of the different companies that belong to our group.

5. WHAT PERSONAL DATA DO WE KEEP?

5.1 WHAT DATA DO WE KEEP WHEN YOU VISIT OUR WEBSITE?

En ASIGNO receives data, either because you actively provide it to us as a data subject or you are browsing our Website. The IP protocol address of your device is recorded, as well as the data on the program you are using to browse, your operating system, the date and time of access and the website address through which you access to the Website.

You are informed that this information is used to determine the technical resilience of our systems in relation to the traffic, loading time of our website and the number of visitors. It is a tool to check the correct functioning of our Website service in real time, in order to improve its performance and offer better services to our Users at all times.

5.2 ¿QUÉ INFORMACIÓN RECABAMOS EN EL RESTO DE LAS SITUACIONES Y FINALIDADES?

En ASIGNO gathers and stores limited personal data always on the basis of the principle of minimum data. In all cases, we gather and process the following:

  1. If the purpose is to manage an enquiry based on our legal-financial and debt recovery services. Identification details: name, surname, electronic contact address, contact identification details, professional mail and electronic address, professional telephone number.
  2. If the purpose is to provide a legal-financial or debt recovery service contracted and correctly manage the contractual relationship and keep you timely informed of the legal services provided: contact identification details, including your Identity Card Number, professional mail and electronic address, professional telephone number, date of birth, passport number, details of the office held on the company's governing body. Identification details related to your visit to our installations. Data relating to invoicing and payment, tax data. Data relating to employment and the job performed. Handwritten signature. Digital signature. Bank account number and other data necessary to prevent fraud and legal information required in relation to anti-money laundering.
  3. If the purpose is to keep our client timely informed with information on services and legislative developments of interest, news, promotional and marketing circulars, information on events organized by the LENER GROUP, we will only record your contact details and electronic mail or postal address.
  4. If the purpose is to manage a staff selection process, we will record your identification details, photograph and National Identity Card No., as well as curriculum data related to your education and professional experience and other data that you voluntarily include in your CV.

6. PRESERVATION OF YOUR DATA

We will keep the data for as long as there is a contractual relationship with you as a User and/or for the time necessary to process any request for information regarding our legal services, or as long as you do not exercise your right of elimination, cancellation and/or limitation of data processing. In any case, for the management of your request for information made through our Website, ASIGNO will proceed to keep the data until the total resolution of your request for information. In the event your data is blocked, your information will always be kept without any use or processing for as long as may be necessary to exercise a claim or any type of judicial, legal or contractual liability may arise from its processing that must be attended to and for which reason it must be recovered.

Likewise, regarding the preservation of the personal data of those interested in joining our organization who participate in a selection process and send us their CV, please note that the period we keep your data will be the necessary time as explained above, until the position you have applied for or for which you are eligible according to your profile has been awarded or you exercise your right of cancellation; in any case, the maximum period of conservation will be two (2) years, after which cancellation will be carried out.

7. WHO WILL WE PROVIDE YOUR DATA TO?

All the data you provide us may be notified to other companies belonging to the Lener Group for them to attend to enquiries on our legal services by a User for the above-mentioned purposes and on the basis of ASIGNO’s legal interest in replying to the request for information. The companies that belong to the Group are: LENER ASESORAMIENTO EMPRESARIAL, S.L.P. (with registered address at Paseo de la Castellana, Núm. 23, Esc. 1-1º Piso, 28046, Madrid C.I.F. B-02977957), Asigno Servicios Integrales de Recuperación de Créditos (with registered address at Paseo de la Castellana, Núm. 23, Esc. 1-1º Piso, 28046, Madrid and C.I.F. B-85.736.023), Lener Administraciones Concursales, S.L. (with registered address at Paseo de la Castellana, Núm. 23, Esc. 1-1º Piso, 28046, Madrid and C.I.F. B-86.598.968), Lener Corporate Finance, S.L. (with registered address at Paseo de la Castellana, Núm. 23, Esc. 1-1º Piso, 28046, Madrid and C.I.F. B-86.978.566), Tax Master Gestión, S.L. (with registered address at C/Colón, 12, 4ª, 36201, Vigo and C.I.F. B-36.972.867).

In particular ASIGNO informs those interested in participating in a selection process that, in order to manage their application, their data may be notified to the companies belonging to the Lener Group listed above, on the legal basis of ASIGNO’s legitimate interest, as it carries out the selection process for all the companies of our Group through a staff selection tool used for the entire group and if the interested party is eventually selected, the candidate's basic data will be notified to the Group company for which the selection has been made, always for it to comply with its legal obligations and those related to the candidate’s professional career.

We also inform you that in these same cases, when your data is provided for the purpose of participating in a current or future selection process, it may be accessed by suppliers who provide services to ASIGNO such as content hosting services. ASIGNO has signed the corresponding data processing contracts with each of the service providers in order to guarantee that these providers will process your data in accordance with the legislation in force. No international transfer will take place of the data belonging to persons that take part in a selection process.

Finally, we inform you that the personal data of Users and of the persons interested in participating in a selection process will be available to the Public Administration, Judges and Courts, in relation to any possible claim arising from the processing of your data.

8. HOW CAN YOU CONTACT ASIGNO AND EXERCISE YOUR RIGHTS?

ASIGNO ha asumido un fuerte compromiso tanto con el derecho fundamental a la protección de datos de carácter personal, como a la privacidad de sus Usuarios. Por tal motivo los datos que puedan ser recabados por nosotros, a través de este sitio Web, solo serán tratados para la finalidad solicitada por el Usuario, no para ningún otro fin.

ASIGNO, informs you that you have full control over all the data you provide us, in terms of your rights as a data subject and User.

Specifically, Users or those interested in participating in a selection process may exercise the following rights free of charge:

  1. Right to access your personal data in order to be aware of what data is being processed and the processing operations carried out;
  2. Right to rectify any inaccurate personal data;
  3. Right to eliminate your personal data, when possible;
  4. Right to request the limitation of the processing of your personal data when the accuracy, lawfulness or necessity of the processing is doubtful, in which case it may be kept for defence against your claims.
  5. The right to portability of your personal data, when the legal basis for its processing includes legitimate interest.
  6. Right to revoke your consent at any time.

You can exercise your rights free of charge at any time by writing to ASIGNO SERVICIOS INTEGRALES DE RECUPERACIÓN DE CRÉDITO, S.L., Paseo de la Castellana, No. 23, 28046 – Madrid (SPAIN) or by sending a request by email together with a photocopy and/or scanned copy of the data subject’s National Identity Card to privacidad@grupolener.es and indicating the right you wish to exercise, as well as your identification details.

You can also contact our DATA PROTECTION OFFICER, for example, if you consider that we have not processed your data correctly, at the email address: dpo@grupolener.es. You are also entitled to file a claim with the Spanish Data Protection Agency either on its website (www.agpd.es), or by writing to its postal address: (c/ Jorge Juan, 6, 28001 - Madrid).

9. PROTECTION OF YOUR DATA: SECURITY MEASURES

ASIGNO has adopted the necessary technical and organizational measures to guarantee the security and integrity of your data, as well as to avoid its alteration, loss, unauthorized processing or access. The information access services are executed in a secure environment, using protocols for the protection of the data provided. The secure server establishes a connection so that the information transmitted is encrypted. The User can verify that he/she is in a secure environment if a closed padlock appears in the status bar of his/her browser. This mechanism allows the User to verify the identity of the owner of the website with which he/she is exchanging data.

ASIGNO is committed to protecting your personal information. In order to safeguard the security of your personal data, we inform you that ASIGNO has taken the necessary technical and organisational measures to ensure the security of the personal data supplied, including but not limited to:

  1. Pseudonymisation and encryption of personal data where appropriate.
  2. The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services.
  3. The ability to restore availability and access to personal data in a timely manner in the event of a physical or technical incident.
  4. A process of regular verification, evaluation and assessment of the effectiveness of technical and organizational measures to ensure the security of processing.

ASIGNO is proactively involved in and committed to the security and confidentiality of your personal data and information. ASIGNO has therefore taken several security measures and technical means to achieve a high level of security and to protect the security, confidentiality and privacy of your personal data.

10. UPDATING OF THIS PRIVACY POLICY

ASIGNO reserves the right to review and update this Privacy Policy, at least every six (6) months, or whenever there is any modification in our processes or a relevant regulation on data protection is applicable. If we have your e-mail address, we will send you complete information on the changes that occur in this Privacy Policy. If and when it is legally necessary, we will proceed to renew your consent, so that you can confirm that you agree and give your consent to the changes or updates made.

The information contained in this Privacy Policy was updated on May 30, 2018.

11. CONTACT ASIGNO

You can contact ASIGNO for any issue relating to this Privacy Policy or any other reason through our customer service department or by sending an email to the DATA PROTECTION OFFICER, at the aforementioned address: dpo@grupolener.es.

12. GOVERNNG LAW AND JURISDICTION

ASIGNO informs you that its relationship with any User of this Website, or any candidate interested in forming part of our organization will be governed by Spanish law in force and all disputes will be resolved by the Courts and Tribunals of Madrid (city).