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Privacy Policy
Following the principles of legality, loyalty, and transparency, we provide you with this Privacy Policy.
The privacy policy described below is applicable to this website, especially concerning the data collected from users and, if applicable, candidates of Overlap Consultores en Marketing y Formación, S.A. (hereinafter, “Overlap“).
It is informed to the interested party that Overlap disclaims any responsibility for the different privacy and personal data protection policies that may be contained in websites accessible through hyperlinks located on this website and not directly managed by Overlap.
Overlap wishes to inform the users of this website that this privacy policy reflects the data protection policy followed by Overlap. This policy has been configured in strict compliance with the current regulations on the protection of personal data, including, among others, Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, regarding the protection of individuals concerning the processing of personal data and the free movement of such data (hereinafter, “GDPR”), as well as Organic Law 3/2018, of December 5, on the Protection of Personal Data and the guarantee of digital rights (hereinafter, “LOPDGDD”).
Who is the Data Controller?
| DATA CONTROLLER | Overlap Internacional, S.A (hereinafter, “Overlap”) | |
| TAX IDENTIFICATION NUMBER | A82095449 | |
| REGISTERED OFFICE | Avda. del Partenón, 10 – 28042, Madrid | |
| CONTACT | [email protected] | |
| Phone number | 917 21 02 21 | |
| DPO | [email protected] | |
For what purpose, legitimacy, and until when will we process your personal data?
At Overlap, depending on the category of data subject and the purpose, data will be processed with different legal bases and retention periods:
| Purpose | Legal bases | OVERLAP will process your data until: |
| The management of inquiries through the Website using the ‘Contact’ form. | Consent (Article 6.1.a GDPR): The User must provide their consent for the processing of their data before submitting the Contact form. | The resolution of the inquiry. |
| Management and receipt of the candidate’s curriculum vitae (CV) through the dedicated form | Consent (Article 6.1.a GDPR): The User must provide their consent for the processing of their data before submitting the candidate’s information. | One (1) year from the receipt of the curriculum vitae. |
| The management of any type of computer incidents that may occur on the Website. | Legitimate Interest (Article 6.1.f GDPR): Overlap has a legitimate interest in managing any computer-related incidents that may occur on the Website. | The resolution of the computer incident. |
| The sending of commercial communications via electronic means related to the services offered by OVERLAP. | Consent (Article 6.1.a GDPR): The User must give their consent for Overlap to process their data for the purpose of sending commercial communications. | The revocation of the express consent by the User. |
| The tracking of the User’s navigation on the Website by using cookies. | Consent (Article 6.1.a GDPR): The User must consent to Overlap installing cookies in their browser. | The persistence periods of each cookie or the uninstallation of them are determined by the User in their browser. |
The User is informed that, after the retention period shown in the table above ends, Overlap will keep their data duly blocked for the sole purpose of addressing any liabilities of any kind that may arise. Personal data will be deleted when such liabilities prescribe. In this regard, Overlap has developed a Data Retention, Prescription, and Deletion Policy.
Overlap’s collection of data from website users is voluntary, and users are not obliged to provide their personal information either through email or by filling out forms.
The data we request from you is appropriate, relevant, and strictly necessary, and you are in no way obligated to provide them. However, not providing this information may affect the purpose of the service or make it impossible to provide the service.
If the user does not wish for Overlap to process their personal data, they should refrain from sending emails and filling out forms on the website. In any case, Overlap will inform the user of the conditions under which personal data is collected, the purposes for which it will be used, whether it is obligatory to provide such data, the user’s rights, how to exercise those rights, and any other necessary additional information.
To which recipients will your data be communicated?
Overlap will not disclose your data to any third parties unless expressly informed otherwise. However, certain entities subcontracted by Overlap (as data processors) may access personal data and information to assist Overlap in managing the website. Overlap ensures that all these entities comply with data protection regulations, which also apply directly to them.
Additionally, we inform you that certain data, in accordance with current regulations or the contractual relationship maintained by Overlap, may be disclosed to:
• Banks and financial institutions for the collection of contracted services and/or purchased products.
• Public administrations with authority in the sectors of Overlap’s activities when required by current regulations.
Sending electronic communications
As mentioned earlier, in the event of having the express consent of the user for sending informative electronic communications regarding the activity, services, and updates of Overlap, related to their business consulting and training sector, electronic communications will be sent. In this regard, the user can unsubscribe or object to receiving these communications through the mechanism provided in each of the messages. Additionally, you can exercise your right to object or withdraw your consent by writing to [email protected].
In this regard, we inform you that, in order to send these electronic communications, Overlap uses Active Campaign, managed by Active Campaign LLC. Since this company is located in the United States, we have implemented and perfected the Standard Contractual Clauses. You can request more information in their Privacy Policy, available here.
What are your rights when you provide us with your data?
The data protection rights that individuals may exercise, when applicable, are:
| Right | What does it consist of? |
| Right of Access | To check what personal data Overlap processes. More information, here. |
| Right of Rectification | To modify personal data that Overlap processes when they are inaccurate, incorrect, or incomplete. More information here. |
| Right of Objection | To request that Overlap does not process your personal data for specific purposes. More information here |
| Right of Erasure | To request that Overlap deletes your personal data. More information, here. |
| Right of Limitation | To request that Overlap limits the processing of your personal data. More information, here. |
| Right of Portability | When processing is carried out by automated means, to receive your personal data in a structured, commonly used, machine-readable format, and to transmit it to another data controller. More information, here. |
| The right not to be subject to automated individual decisions. | This right aims to ensure that you are not subject to a decision based solely on the processing of your data, including profiling, that has legal effects on you or significantly affects you in a similar way. More information, here. |
| Right to file a complaint with the competent authority. | To file a complaint against Overlap with the Spanish Data Protection Agency (AEPD) if the User believes that the entity has processed their personal data in violation of regulations. |
The holders of the personal data obtained may exercise their rights of personal data protection by sending a written communication to the registered office of Overlap (Avda. del Partenón, 10 – 28042, Madrid), or to the email address set up for this purpose, [email protected].
You can use the following templates to exercise your rights:
- Access to the template to exercise the right of access
- Access to the template to exercise the right of rectification
- Access to the template to exercise the right of erasure.
- Access to the template to exercise the right of objection.
- Access to the template to exercise the right to restrict processing.
- Access to the template to exercise the right to data portability.
- Access to the template to exercise the right not to be subject to automated individual decision-making.
More information about exercising your rights can be found on the official website of the Spanish Data Protection Agency (hereinafter, “AEPD”) at the following link.
Can I withdraw my consent?
You have the option and the right to withdraw your consent for any specific purpose granted at the time, without affecting the legality of the processing based on the prior consent before its withdrawal.
Where can I file a complaint if I believe that my data is not being treated correctly?
If any data subject believes that their data is not being treated correctly by Overlap, or that requests to exercise their rights have not been satisfactorily addressed, they can file a complaint with the relevant data protection authority. In the national territory, the appropriate authority is the Spanish Data Protection Agency (AEPD), located at Calle Jorge Juan, 6 – 28001, Madrid. For more information, here.
Security and Updating of Your Personal Data
In order to safeguard the security of your personal data, we inform you that Overlap has implemented all the necessary technical and organizational measures to ensure the security of the provided personal data. This is done to prevent their alteration, loss, and/or unauthorized processing or access, as required by the regulations, although absolute security is not possible.
It is important that you keep us informed of any changes to your personal data so that we can maintain them up to date.
Confidentiality
Overlap informs you that your data will be treated with the utmost care and confidentiality by all personnel involved in any phase of the processing. We will not transfer or disclose your data to any third party, except as legally required, or unless the data subject has expressly authorized us.
Modification of Privacy Policy
Overlap may modify its Privacy Policy in accordance with the applicable laws at any given time. Therefore, we recommend reading it every time you access the website or carry out any procedures with our organization.
Cookies
The website uses its own and third-party cookies that are necessary to allow the user to enjoy all the functionalities of the website and to track their browsing habits. If you wish to learn more about the types of cookies that OVERLAP installs on your browser, you can do so through our Cookie Policy.