Privacy Policy - MatraX Lubricants

In compliance with what is stipulated in the current regulations on personal data protection, the following information is provided:

1. INFORMATION FOR THE INTERESTED PARTY AND/OR USER

INDUSTRIAL QUÍMICA RIOJANA, S.A. makes this privacy policy available to provide you with detailed information about how the personal data that is or will be provided by you as an interested party and/or user, by any means such as through the website, via email, telephone, in person, through on-line or paper forms, etc.) is being or will be processed.

INDUSTRIAL QUÍMICA RIOJANA, S.A. has adopted all the necessary technical and organisational security measures to guarantee the integrity, confidentiality and availability of the personal data in their custody.

Responsibility of the interested party and/or user

By providing your data, you as an interested party and/or user (hereinafter the Interested party), guarantee that you at least 18 years old and that the data provided to INDUSTRIAL QUÍMICA RIOJANA, S.A. are true, accurate, complete and current. For these purposes, the interested party acknowledges that the communicated data is true and that they will keep this data updated to ensure they reflect their actual situation and shall be liable for any data they provide that is false and inaccurate as well as for any damages, direct or indirect, that could be derived from data that is false or inaccurate.

2. DATA PROCESSOR

Identity: INDUSTRIAL QUÍMICA RIOJANA, S.A.

NIF (TAX ID): A26020198

Postal address: Carretera de Lodosa, s/n. – 26510 Pradejón (La Rioja). E-mail: calidad@iqrsa.es Telephone: 941150302

Electronic mail: calidad@iqrsa.es

3. PURPOSES, DATA RETENTION PERIOD AND LAWFULNESS OF THE PROCESSING

INDUSTRIAL QUÍMICA RIOJANA, S.A., as the company Responsible for Processing personal data (Data Processor) from the Interested party, as well as any other data that may be supplied in the future, informs you that this data will be processed in accordance with current regulation on personal data protection and therefore the following information is provided regarding each process that is carried out by INDUSTRIAL QUÍMICA RIOJANA, S.A.:

CONTACT / QUERIES

Reason for processing personal data: answer questions and follow up on any queries, requests for information, suggestions and claims as well as for staying in contact with people who have shown an interest in the company, its products or services.

Data retention criteria: the information shall be kept for the time required for processing and responding to the query.

Lawfulness of processing the data: RGPD: 6.1.f) the legal basis for processing the data is based on the legitimate interest of the Data Processor and responding to any received communications or requests.

BULLETIN/NEWSLETTER SUBSCRIPTION

Reason for processing personal data: manage sending informative newsletters/bulletins about the Data Processor, its products and services.

Data retention criteria: the information shall be kept in the system indefinitely as long as the interested party does not request the information be deleted.

Lawfulness of processing the data: RGPD: 6.1.a) the legal basis for processing the data is the consent provided by the interested party at the time they subscribed to the bulletin/newsletter.

COMMENTS

Purpose of the processing: Moderate and publish opinions about a publication on the website.

Data retention criteria: the information shall be kept in the system indefinitely as long as the interested party does not request the information be deleted.

Lawfulness of processing the data: RGPD: 6.1.a) the legal basis for processing the data is the consent provided by the interested party at the time they entered a comment or opinion.

PROFORMA INVOICES / COST ESTIMATES

Purpose of the processing: drafting and delivering the proforma invoices and/or cost estimates requested by interested parties as well as follow-up on these by telephone, telematically or in person.

Data retention criteria: the data shall be kept as long as a mutual interest exists to do so or the interested party request the data be deleted.

CUSTOMERS

Reason for processing the personal data: managing and contracting products and services offered by our company, manage clients, maintaining contractual and/or commercial relationships with them as well as for administrative (invoicing, collection, payments, etc.), accounting and tax purposes and to comply with the legal obligations related with the aforementioned.

Personal data may also be processed to establish contact with persons that provide services at a corporate body (company, organisation, etc.), as well as individually owned businesses and freelance professionals, to establish or maintain a business relationship («business to business», B2B) with them.

Data retention criteria: the data shall be kept as long as a contractual/business relationship exists between both parties and a request has not been received to delete the information. In cases where such a request has been received, the data shall be kept as required by current regulations (tax, business, etc.) in terms of the statute of limitations.

Lawfulness of processing the data: RGPD: 6.1.b) the legal basis for processing the data is to execute and maintain the contractual/business relationship between both parties as well as to comply with the legal obligations (tax, business, etc.) related with the aforementioned.

The processing of contact data of a professional nature for business type relationships is lawful because of the legitimate interest of the Data Processor to be able to contact, establish and/or maintain business type relationships with the corporate body where the interested party is providing their services as well as with individually owned businesses and freelance professionals (RGPD: 6.1.f and LOPDGDD: 19).

SENDING OF COMMERCIAL COMMUNICATIONS

Purpose of the processing: send information using any method such as postal or electronic mail regarding events, activities, offers, products, services and rest of information from the Data Processor, which could be of interest to the interested party.

Data retention criteria: the information shall be kept in the system indefinitely as long as the interested party does not request the information be deleted.

Lawfulness of processing the data: RGPD: 6.1.f) the sending of commercial information to clients is based on the legitimate interest of the Data Processor of sending commercial communications about its products or services similar to those contracted for the purpose of earning the loyalty of their clients.

RGPD: 6.1.a) The basis for sending commercial information to non clients is the consent provided by the interested party at the time the data is collected.

However, in any of these two cases, the interested party has the right to object to the handling of their data and may do so by any of the means described in this document.

Under no circumstance shall the withdrawal of consent affect the maintaining of commercial relationships. Also, the handling of data that occurred beforehand for this purpose shall not become unlawful because the consent has been withdrawn.

Origin of the data: the personal data we process originates from: The categories of the data that is processed are: identifying information (name and surnames, Tax ID, postal address, telephone, email) and professional type information (position, work location, sector of activity).

SUPPLIERS

Reason for processing the personal data: managing suppliers, maintaining contractual and/or commercial relationships with them as well as for administrative (invoicing, collection, payments, etc.), accounting and tax purposes and to comply with the legal obligations related with the aforementioned.

SENDING OF CV

Reason for processing the personal data: filing and registering the documentation that is provided voluntarily by the interested parties for future candidate hiring processes for positions at the company.

Data retention criteria: the data shall be kept for a maximum period of one year or until the interested party exercises their right to delete their data.

In this regard, after said time period has elapsed and you wish to continue participating in the selection processes conducted by the Data Processor, we ask that you please resubmit your CV.

Lawfulness of processing the data: RGPD: 6.1.a) the legal basis for processing the data is the consent provided by the interested party at the time they supplied their personal data to participate in selection processes.

CONTESTS / RAFFLES / PROMOTIONS

Purpose of the processing: manage and organise the participation of interested parties in the raffles, contests or promotions conducted by the Data Processor and sending any communication related with the organising thereof, and in cases where an interested party wins any of these events, for publishing the name and/or brand in any media the Data Processor deems appropriate, as well as on its websites, social networks and promotional material in general for the purpose of advertising the activities carried out by the Data Processor.

Data retention criteria: the data shall be kept as long as it is required for processing and when it is no longer required for this purpose, during the time required by current legislation in terms of the statute of limitations.

Lawfulness of processing the data: RGPD: 6.1.a) the legal basis for processing the data is the informed consent that is requested at the time the data for participating is collected.

RGPD: 6.1.f) The publishing of data related with the result of the contest/raffle is based on the legitimate interest of the Data Processor in accordance with the promotional and distributing interests as well as operating the event.

RECORDING OF ACCESSES TO THE INSTALLATIONS

Reason for processing the personal data: controlling and managing personnel accessing the installations to comply with the regulations on occupational risk prevention and food safety and hygiene.

Data retention criteria: the data shall be kept for the time required to comply with the purpose for which the data was collected and to determine the possible responsibilities that may be derived from retaining and processing the data. Occupational risk prevention and food safety regulations (BRC, IFS, etc.) shall apply.

Lawfulness of processing the data: RGPD: 6.1.f) the legal basis for processing the data is the legitimate interest of the Data Processor in complying with the regulations on occupational risk prevention and food safety and hygiene as well as to comply with all applicable legal obligations.

4. TRANSFERING OF DATA

In general, personal data will not be transferred to third parties except in cases where there is a legal obligation to do so, or when it is required for providing the services or for maintaining and developing relationships with the following entities, including but not limited to:

Public Administrations, Judges and Courts; to comply with legal obligations and to determine possible responsibilities originating from the processing in accordance with applicable regulations.

Financial/banking institutions; for managing collections and payments.

When not concerning the transfer of data, to carry out any of the indicated processing of data or to provide a service, third party companies acting as the Data Processor (our suppliers), access your information to carry out the mentioned processing of data or service. These responsible parties access your data following our instructions and without being able to use your data for other purposes; all while maintaining the data strictly confidential.

International transfers

INDUSTRIAL QUÍMICA RIOJANA, S.A. does not plan to transfer personal data to any country outside the European Economic Area (EEA). In cases where required, data will only be transferred to parties located in a country, territory or one or several specific sectors in that country or international organisation that has been designated by the European Commission as having a suitable level of protection; or fall under the Privacy Shield agreement; or are covered by any of the suitable guarantees stipulated in article 46.2 of Regulation (EU) 2016/679

5. RIGHTS OF INTERESTED PARTIES

Any person has the right to obtain confirmation regarding whether or not a responsible party is processing their personal data as well as withdrawing the consent they may have provided for a specific purpose at any time, without this affecting the legality of the processing based on the consent provided prior to the consent being withdrawn.

The regulation on personal data protection enables you to exercise your right to access, correct, transfer and delete your data and to limit or object to the processing of your data as well as not being subject to decisions based solely on an automated processing of your data, when applicable.

These rights are characterised by the following:

The exercising of these rights is free, unless the requests are manifestly unfounded or excessive (e.g. repetitive), in which case the Data Processor may charge a fee that is proportional to the administrative cost of answering the request or may otherwise refuse to act.

You may exercise these rights directly or through a legal or voluntary representative.

We must process your request within one month; however, depending on the complexity and number of requests received, this deadline may be extended by two additional months.

We have the obligation of informing you regarding the means available for exercising these rights, which shall be accessible and the exercising of your right cannot be denied for the sole reason of you opting to use a different means to exercise your right. If the request is submitted electronically, the response will be supplied through this channel whenever possible, unless you request it be provided in a different manner.

If the Data Processor does not process the request, they shall notify you, no later than within one month at most, regarding the reasons why they have not acted and the possibility of submitting a claim with the Control Authority.

How to exercise these rights?

Interested parties may exercise their rights by sending a letter to the postal address or via an email addressed to the Data Processor, entering “EXERCISING OF LOPD RIGHTS” in the subject line and including: the nature of the request, address for notification purposes, date and signature. Interested parties may also exercise their rights through a legal representative, in which case, in addition to the DNI of the interested party, they must provide the legal representative’s DNI as well as a document certifying they are being represented by a the third party.

Interested parties shall provide proof of their identity by providing a photocopy or scanned copy of their DNI or equivalent document so we can verify that we are only answering the interested party or their legal representative, in which case, a document shall be supplied proving said representation.

If requested we will provide the forms you may use to exercise these rights by telling us which right you wish to exercise.

Likewise and especially if we consider that you are not fully satisfied in terms of the exercising of your rights, we inform you that you may submit a claim to the National Control Authority by sending a letter to Agencia Española de Protección de Datos, C/ Jorge Juan, 6 – 28001 Madrid.

6. SOCIAL NETWORKS

INDUSTRIAL QUÍMICA RIOJANA, S.A. uses social networks, which is another method used for reaching you. The information collected via messages and communications you publish may contain personal information that is available on-line and accessible to the public. These social networks have their own privacy policies explaining how they are used and share your information; therefore, we recommend reading the policies prior to using these social networks to confirm that you agree with the way your information is collected, processed and shared.

The data processing that is carried out by personnel that follow and/or carry out any type of action such as linking or connecting through the social networks of the official pages of the Data Processor, shall adhere to this privacy policy and to the privacy policies of said social networks.

The Data Processor will process your data for the purpose of properly managing your presence on the applicable social network, sending personal and individual messages using social network channels, inform you of the activities, products and/or services offered by the Data Processor or third parties that may be related with their activity, as well as any other processing allowed by the social networks’ regulations.

7. COOKIES

In general, when browsing the internet, you can accept or reject cookies via the configuration options of your browser.

This website may use cookies and other similar technologies such as local shared objects, flash cookies or pixels, which are small files that some platforms such as websites may install on the user’s device (computer, tablet, Smartphone, etc.).

Its functions may be varied: save browsing preferences, compile statistical information, allow certain technical functionalities, save information about the browsing habits of the user or its device, etc.

Cookies are useful for various reasons. From a technical point of view, they allow websites to operate faster and adapted to the user’s preferences like for example, save their language or the currency of their country, etc. Additionally, they help website Data Processors improve their services and make the advertisements they broadcast more efficient thanks to the statistical information of habits that are collected through them.

For the installation and use of specific cookies, we must obtain the informed consent of the users. Cookies requiring user consent are, among others, analytical, advertising and affiliated cookies. An exception to this are technical cookies as well as those required for operating the website or providing services that have been expressly requested by the user.

The user is able to configure their browser to be alerted when cookies are received and may prevent them from being installed on their computer. Please consult your browser’s instructions for further information on cookies. For more information about cookies please consult our Cookies Policy.

8. MANDATORY OR OPTIONAL NATURE OF THE INFORMATION PROVIDED BY THE INTERESTED PARTY

Interested parties, by checking the applicable boxes and entering data in the fields identified as mandatory in the different forms, expressly, freely and unequivocally accept that their data is required by the Data Processor to process their request and the entering of data in the remaining fields is voluntary.

In cases where all the required data is not supplied, said data cannot be processed and therefore, the petitions, contracting or requests made by the interested party cannot be attended.

The interested party guarantees that the personal data that is supplied is true and shall be responsible for communicating any change that occurs related with this data.

9. SECURITY MEASURES

INDUSTRIAL QUÍMICA RIOJANA, S.A. undertakes to protect your personal information: Using measures, controls and procedures of a physical, organisational and technological nature that are reasonably reliable and effective and focussed on preserving the integrity and security of your data and guarantee their privacy.

Additionally, all personnel with access to personal data have been trained and are knowledgeable about their obligations related to the processing of personal data.

In the case of contracts entered with suppliers, we include clauses that require they maintain the personal data secret that they have had access to as a result of the order that is placed, as well as implementing the technical and organisational security measures required for guaranteeing the confidentiality, integrity, availability and permanent resilience of the systems and services used for processing personal data.

All these security measures are reviewed periodically to guarantee they are suitable and effective.

However, absolute security cannot be guaranteed and there is no security system in existence that is impenetrable; therefore, in cases where any information subject to processing and under our control becomes compromised as a result of a security breach, we will take all the proper actions to investigate the breach, notify the Control Authority and if applicable, the interested parties that may have been affected so they can take proper actions.