Privacy Policy
1. Initial information
PENSIUM, S.L. considers your personal information to be very important. We therefore handle it confidentially and securely. We are committed to protecting the privacy of personal data at all times and to not collecting unnecessary information.
You do not need to register in advance to access our website. If you need further information, you can contact us using the forms available on our website, provided that you agree to our Privacy Policy. You must accept this policy to record your express consent to the processing of data for the purposes stated.
In accordance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and Organic Law 3/2018 of 5 December on Personal Data Protection and the Guarantee of Digital Rights, we provide information about the processing of your data in this Privacy Policy.
2. Who processes the data?
- Identity: PENSIUM, S.L.
- Tax ID (NIF): B66834904
- Registered address: C/ Mallorca, 214 – 2 1B 08008 Barcelona (Barcelona)
- Email: info@pensium.es
3. What data processing do we carry out, for what purposes and for how long?
| DATA PROCESSING | PURPOSE AND LEGAL BASIS | RETENTION PERIOD |
|---|---|---|
| Website operation | To manage the proper functioning and operation of the website: personal data will be processed only insofar as strictly necessary to provide and ensure the security of the application and information. The legal basis is the legitimate interests pursued by the controller, in accordance with Article 6(1)(f) of the GDPR. | The data collected will be retained for the time strictly necessary to fulfil the purpose for which it was collected and, in any event, to determine any potential liability arising from that purpose, taking account of the periods established by applicable legislation. |
| Contact | To respond to requests and/or enquiries made by users. The legal basis for processing is express consent under Article 6(1)(a) of the GDPR. | Data will be retained until the request has been resolved. It may, in any event, be retained to determine any potential liability arising from this purpose. |
| Company updates and newsletter | Subscription to company news, promotions and offers. The legal basis is express consent under Article 6(1)(a) of the GDPR and Article 21(2) of Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI-CE).
Where a contractual relationship exists, commercial communications concerning products or services similar to those already contracted may be sent on the basis of our legitimate interests under Article 6(1)(f) of the GDPR. |
Data will be retained for as long as the newsletter subscription remains active or until the data subject exercises the right to object or to erasure. It may, in any event, be retained to determine any potential liability arising from this purpose. |
| Email management | To respond to enquiries received and manage commercial and/or professional relationships. The legal basis is the contractual relationship between the data controller and the data subject, under Article 6(1)(b) of the GDPR. | The data collected will be retained for the time strictly necessary to fulfil the purpose for which it was collected and, in any event, to determine any potential liability arising from that purpose, taking account of the periods established by applicable legislation. |
| CV management | Data will be processed to handle the application and assess the applicant’s profile for participation in recruitment processes. The legal basis is express consent under Article 6(1)(a) of the GDPR. Where the company publishes a job vacancy, processing will be lawful where necessary to take pre-contractual steps at the applicant’s request or with a view to entering into a contract, pursuant to Article 6(1)(b) of the GDPR. |
Data will not be kept for longer than necessary for the purposes for which it was collected, unless a legal obligation applies. In that case, it will be retained for a maximum period of one year. |
| Request for the Pensium Guide | Data collected through the Pensium Guide request form will be processed to send users the information guide to the Pensium programme and, where appropriate, to respond to enquiries arising from it. The legal basis is express consent under Article 6(1)(a) of the GDPR. | Data will be retained until the request has been handled. It may, in any event, be retained to determine any potential liability arising from this purpose. |
| Social media | To manage user interactions with PENSIUM, S.L. profiles on social media (YouTube, Facebook, LinkedIn and Instagram). The legal basis is the user’s consent when following and interacting with these profiles, in accordance with Article 6(1)(a) of the GDPR. Processing carried out by each social network is governed by its own privacy policy. | Data will be retained for as long as the user remains connected to the PENSIUM, S.L. profile on the social network, or for as long as that profile remains active. |
| Satisfaction surveys, reviews and testimonials | To send satisfaction surveys, service reviews or quality questionnaires to users of the Pensium Programme for statistical purposes and to improve service quality. The legal basis is the controller’s legitimate interests under Article 6(1)(f) of the GDPR. The publication of opinions and testimonials on the website (identified by initials and locality) will be based on the data subject’s express consent under Article 6(1)(a) of the GDPR. |
Data will be retained for the time necessary to prepare statistical studies and, in the case of testimonials, until the data subject withdraws consent. It may, in any event, be retained to determine any potential liability arising from this purpose. |
| Complaints service | To handle complaints and claims submitted to the Pensium Group Complaints Service (reclamaciones@pensium.es, by post or at offices open to the public). The legal basis is compliance with a legal obligation applicable to the controller in its capacity as a real estate credit intermediary, in accordance with Article 6(1)(c) of the GDPR. | Data will be retained until the complaint has been resolved. It may, in any event, be retained to determine any potential liability arising from this purpose. |
| Prevention of money laundering and terrorist financing | Where services are contracted, to verify the client’s identity, professional or business activities, any status as a politically exposed person, and the lawful origin of funds. The legal basis is compliance with a legal obligation under Article 6(1)(c) of the GDPR and Law 10/2010 of 28 April on the Prevention of Money Laundering and Terrorist Financing. | Data will be retained for ten years from the end of the business relationship or the execution of the transaction, in accordance with Article 25 of Law 10/2010. |
| User access (private area) | To allow users of the Pensium Programme to access the private area via the “USER ACCESS” link on the website. The legal basis is performance of the contractual relationship under Article 6(1)(b) of the GDPR. | Data will be retained while the contractual relationship remains in force. It may, in any event, be retained to determine any potential liability arising from this purpose. |
| Blog comments | To manage, moderate and, where appropriate, publish comments that users submit on articles in the website blog through the “Leave a reply” form, and to respond to them. The data processed comprises the comment, name and email address (mandatory), and optionally the user’s website. The legal basis is the user’s express consent under Article 6(1)(a) of the GDPR. The name provided and the comment content will be publicly visible on the website. The email address will not be published. |
Data will be retained for as long as the comment remains published on the website or until the user requests its erasure or withdraws consent. It may, in any event, be retained to determine any potential liability arising from this purpose. |
4. To whom will data be disclosed?
Except in the circumstances set out below, or where we are legally required to disclose your personal data or you have given us your express consent, we will not disclose your personal data to third parties.
Personal data may be disclosed to PENSIUM DIRECT, S.L. (Tax ID B66990086), a Pensium Group company responsible for the operational and financing functions of the programme, to manage user requests and for internal administrative purposes, on the basis of the controller’s legitimate interests, in accordance with Article 6(1)(f) and Recital 48 of the GDPR.
Data may also be disclosed to public authorities, courts and tribunals, the Bank of Spain and the Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offences (SEPBLAC), where required by law.
Service providers working for PENSIUM, S.L. (web hosting, IT maintenance, web analytics tools, user access platform, etc.) may access the data as processors, subject to the relevant data processing agreements signed in accordance with Article 28 of the GDPR.
5. Are international data transfers carried out?
No international transfers of data are made to third countries outside the European Union.
6. What rights do you have as a user, and how can you exercise them?
Right of access
As a user, you can ask us to explain what we do with your personal data.
You may also request information about the purposes for which your personal data is processed, how long we retain it, your rights as a user, whether your data has been transferred to a third country or international organisation, and whether automated decisions or profiling take place on the website, among other matters.
Right to rectification
If the personal data you have provided to us is inaccurate or incomplete, you have the right to have it corrected or completed. Contact us and we will make the corrections you request.
Right to restriction of processing
As a user, you can request restriction of the processing of your personal data when:
- You contest the accuracy of your personal data, for a period enabling us to verify its accuracy.
- The processing is unlawful and you oppose the erasure of your personal data and request restriction of its use instead.
- We no longer need your data for processing purposes, but you need it to establish, exercise or defend legal claims.
Right to erasure
You can ask us to erase your personal data without delay. We are required to erase it promptly when it is no longer needed for the purposes for which it was collected. You may also request erasure if you withdraw consent, object to processing and there are no justified grounds for continuing it, your data is processed improperly, erasure is required to comply with a legal obligation, or your data was obtained in connection with a legal offer.
Right to information
If you have exercised your right to rectification, erasure or restriction, we are required to inform all recipients to whom your personal data was disclosed of that rectification, erasure or restriction of processing, unless this is impossible or involves disproportionate effort.
As a user, you have the right to be informed by the controller who those recipients are.
Right to data portability
You have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format. You also have the right to transmit it to another controller without hindrance from us.
Right to object
As a user, you have the right to object at any time, on grounds relating to your particular situation, to our use of the personal data you have made available to us.
We will stop processing your personal data unless we have compelling legitimate grounds that override your interests, rights and freedoms, or the processing is necessary to establish, exercise or defend legal claims.
Right to withdraw your data protection consent
As a user, you have the right to change or withdraw your data protection consent at any time. This change of decision does not affect the lawfulness of processing carried out on the basis of the consent given before its withdrawal.
Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
7. Right to lodge a complaint with a supervisory authority
As a user, you have the right to lodge a complaint with a supervisory authority, particularly in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data breaches the GDPR.
8. Where can you exercise your rights?
You can request to exercise your rights by emailing: info@pensium.es
9. Is it mandatory to provide all information requested in data collection forms?
For forms on the website, you must complete the fields marked as “required”. Failure to provide the required personal data, or providing it only in part, may prevent PENSIUM, S.L. from handling your requests. Consequently, PENSIUM, S.L. will not be liable for the non-provision or incomplete provision of the requested services.
The personal data provided by users to PENSIUM, S.L. must be up to date so that records remain accurate and error-free. Users are responsible for the accuracy of the data they provide.
10. What security measures have we implemented?
We inform you that we handle and use your personal data in compliance with current legislation on data protection and information society services.
We have implemented the technical and organisational security measures needed to protect users’ personal data against alteration, loss, unauthorised processing or access, taking account of the state of the art, the nature of the stored data and the risks to which it is exposed, whether arising from human activity or from physical or natural circumstances, in accordance with applicable legislation.
11. Blog comments policy
The blog on the PENSIUM, S.L. website allows users to comment on published articles, with the aim of fostering a respectful and useful space for participation concerning care home funding, care for older people and related matters. Submitting a comment implies acceptance of the rules in this section.
Requirements for commenting
To publish a comment, you must complete the “Leave a reply” form with your comment, name and email address (all mandatory), and optionally your website. You must also read and accept this Privacy Policy by ticking the corresponding box.
Your name and the content of your comment will be publicly visible; your email address will not be published. If you prefer, you may use an alias rather than your full name. You must be over 14 years old to comment, in accordance with Article 7 of the LOPDGDD.
Prohibited content
As a user, you agree not to publish comments that:
- Contravene the law, morality or public order.
- Are offensive, defamatory, discriminatory or violent, or incite hatred.
- Infringe third-party rights, such as rights to honour, personal and family privacy, one’s own image, or intellectual and industrial property rights.
- Include third-party personal data or particularly sensitive personal information about yourself, such as health information, degree of dependency, financial or property circumstances, or contact details.
- Contain advertising, spam, commercial links or content unrelated to the subject matter of the article.
- Contain false or misleading information or impersonate another person.
Comment moderation
Comments may be reviewed before publication. PENSIUM, S.L. reserves the right not to publish comments, to edit them solely to remove personal data or sensitive information, or to remove comments that breach these rules at any time, without prior notice.
Liability
Users are solely responsible for the content of their comments. PENSIUM, S.L. is not responsible for opinions expressed by users. However, in accordance with Articles 11 and 16 of the LSSI-CE, it undertakes to remove or block unlawful content or content that infringes third-party rights as soon as it becomes actually aware of it.
Responses posted by PENSIUM, S.L. on the blog are for general information purposes only and do not constitute personalised advice. If you need an assessment of your individual circumstances, you can contact us using the forms on the website.
Intellectual property
By publishing a comment, the user warrants that they are its author or hold the necessary rights to its content, and grants PENSIUM, S.L. a free, non-exclusive licence to reproduce it and communicate it publicly on the website, in accordance with the website’s Legal Information.
Data protection and removal of comments
Data provided when commenting will be processed as described in Section 3 of this Privacy Policy. You may request the removal of your comments and exercise your rights at any time as explained in Section 8.
If you identify any comment that breaches these rules, you can report it by email to info@pensium.es.