Privacy Policy

1. Purpose

The purpose of this Privacy Policy is to inform all persons who access and browse the Website (hereinafter, the “User”) accessible through the domain name www.pensium.es and its subdomains (hereinafter, “the Website”) about the data processing activities carried out by PENSIUM, S.L. through this Website.
Access to our Website does not require prior registration as a User. However, accessing and browsing the Website implies that the User fully accepts this Privacy Policy and Cookie Policy, as well as the Website’s Legal Notice.

2. Data controller
Owner: PENSIUM, S.L. (hereinafter, “PENSIUM”).
Registered address: Calle Mallorca 214, 2º 1ª puerta B, 08008 Barcelona.
Tax ID (C.I.F.): B-66834904
Telephone: 93 880 64 80
Contact details for exercising rights — Email: info@pensium.es

3. Purposes of data processing

In accordance with the provisions of Regulation 2016/679 of the European Parliament and of the Council 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 (hereinafter, “the GDPR“) and any other regulation that may amend and/or replace it in the future, we hereby inform the User that the data provided to PENSIUM through any online data collection forms will be incorporated into a personal data file owned by PENSIUM and will be processed for the following purposes:

  1. To enable the use of the functionalities made available on the Website, as well as to attend to requests submitted by the User to PENSIUM.

Data processed for this purpose will be retained until such requests have been resolved.

  1. Should the User submit their CV and/or job application to PENSIUM, their data will be processed for the purpose of handling said application and, where applicable, enabling them to participate in a selection process for a position at PENSIUM.
  1. To manage the User’s interactions with PENSIUM through PENSIUM’s social media profiles, including Youtube, Facebook, Google+ and LinkedIn. The data processed for this purpose will be that entered by the User in their profile on each social network, and is therefore governed by the privacy policy of that social network, for which PENSIUM bears no responsibility.

Data processed for this purpose will be retained for the duration of PENSIUM’s profile on the relevant social network.

  1. To keep the User informed, including by electronic means, about PENSIUM’s services and news through commercial communications and/or Newsletters. If you do not wish to receive such communications, you must tick the corresponding box at the bottom of the data collection forms.

Data processed for this purpose will be retained until the User withdraws their consent to receive such communications, or exercises their right to object.

To provide the User with the opportunity to respond to satisfaction surveys, service ratings or quality questionnaires, for statistical purposes and with the aim of identifying areas for improvement in the quality of the service offered and/or in User support. The data provided by Users will be processed in accordance with applicable Data Protection regulations.

Unless expressly stated otherwise in specific fields, the provision of requested personal data shall be voluntary, and the refusal to provide such information shall not result in a reduction in the quality or quantity of the services requested by the User. Failure to complete fields marked as mandatory with an * or the provision of incorrect data will prevent PENSIUM from being able to provide the selected services, process your request or send you the requested information.

The User declares that the data provided is accurate and that, in the event of contracting services, they are acting on their own behalf.

In compliance with applicable regulations on the prevention of money laundering and terrorist financing, which require GRUPO PENSIUM to collect information from its clients about their professional or business activity, as well as other information, the user subscribes to this declaration and accepts responsibility for the accuracy of the data contained therein.
The user declares that the following statement reflects their current situation and, in the event of contracting PENSIUM’s services, undertakes to notify GRUPO PENSIUM, as soon as possible, of any changes that may occur during the contractual relationship, and to provide additional documentation if required under the regulations on the prevention of money laundering and terrorist financing.

Furthermore, the declarant states that they are not, nor are they related to, politicians, public officials or high-level individuals who have held, in the last two years, or are currently holding, important public functions, including senior management positions in trade union or business organisations or political parties in Member States of the European Union or third countries, nor in the Spanish State, nor at the regional or local level (provincial or regional capitals, or local entities with more than 50,000 inhabitants). Should this not be the case, the Client undertakes to expressly notify GRUPO PENSIUM.

That, in the event of contracting, the transaction carried out is not linked to any type of operation related to money laundering or the financing of terrorism, nor is there any suspicion that it could be. Furthermore, the declarant states that the origin of the funds used for the transaction comes from lawful activities that have been duly declared.

GRUPO PENSIUM may cease to execute any transaction or provide the services set out in the service proposal until it is in possession of the requested documentation, for the purposes of the Prevention of Money Laundering and Terrorist Financing. Likewise, GRUPO PENSIUM may suspend the provision of services in the event that, during the course of their execution, circumstances are detected indicating that the risk level of the Client or the transaction is contrary to the aforementioned regulations, and this shall not be considered, under any circumstances, a breach of contract on the part of GRUPO PENSIUM.

4. International Data Transfers

PENSIUM SL does not transfer data to third countries; however, should it require services from companies located outside the European Union or in areas without adequate data protection measures, it will comply with the provisions set out in Chapter V of the GDPR.

5. Legal basis

The legal basis for carrying out the data processing activities specified in the section above is as follows:

  1. The User’s implicit consent in their request, for the purpose of enabling PENSIUM to handle it.
  1. The User’s implicit consent in submitting their CV and/or job application.
  1. The User’s implicit consent by following and interacting with PENSIUM’s profile on the social network.
  1. The User’s explicit consent by ticking the corresponding box to receive such communications.

6. Recipients

In accordance with the processing purposes set out above, the User’s data will be shared with the company PENSIUM DIRECT, S.L. for internal administrative purposes, based on PENSIUM’s legitimate interest and in accordance with Recital 48 of the GDPR, which establishes that controllers forming part of a group of undertakings may have a legitimate interest in transmitting personal data within the group for internal administrative purposes, including the processing of personal data of clients or employees.

Furthermore, please be informed that your personal data will not be communicated to third parties unless such communication is required to fulfil a legal obligation or to provide you with a service. In the latter case, PENSIUM will in all cases enter into the corresponding data processing agreement with each of those third parties, who will process such data exclusively for the purposes determined by PENSIUM in each case.
7. Exercise of rights

The processing of the User’s personal data by PENSIUM will at all times be carried out in accordance with applicable legislation on the protection of personal data and information society services.

Likewise, in relation to the processing of User data for which the legal basis is the consent given by the User, the User has the right to withdraw such consent at any time, without this affecting the lawfulness of the processing carried out on the basis of consent prior to its withdrawal.

In any case, you may exercise your rights of access, rectification, erasure, restriction of processing, portability and objection at any time and free of charge, by sending a written request accompanied by a copy of your national identity document or valid identification document, addressed to PENSIUM, S.L., Calle Mallorca 214, 2º 1ª puerta B, 08008 Barcelona, or to the following email address: info@pensium.es

In any case, the User has the right to lodge a complaint with the relevant supervisory authority if they deem it appropriate.