Privacy Policy

WHISTLEBLOWING CHANNEL PRIVACY POLICY

In accordance with European Regulation 2016/679 (hereinafter, the "GDPR") and Organic Law 3/2018, of 5 December, on the protection of personal data and guarantee of digital rights, we provide you with the following information:

Who is responsible for processing the personal data you provide to ALVINESA NATURAL INGREDIENTS S.A.U.

Name: ALVINESA NATURAL INGREDIENTS S.A.U.

CIF: A30423073

Address: Ctra. Valdepeñas Km. 4,850 Pol. Ind. El Campillo, 13250 Daimiel, Ciudad Real (Spain)

Telephone number: (+34) 926 26 06 70 

E-mail: [email protected]

Web Name: www.alvinesa.com

Data Protection Officer of Alvinesa Natural Ingredients S.A.U.

You can contact the data protection delegate via the following email address: [email protected]

What PROCESSING are we going to do with your data, for what PURPOSE, what LEGITIMACY do we have and how long are we going to keep them ?

Personal data collected

- First name and surname (when provided)

- E-mail address

- Telephone number (When provided)

-Content of the complaint

Purpose (use of data)

The purpose of the processing is to manage your incident notification, carry out the investigation of the reported facts, inform you of the outcome of the procedure, as well as, where appropriate, to take disciplinary measures and/or take legal or other appropriate action before the corresponding bodies.

Why we can use them (legal basis)

The legal basis that legitimises the processing of personal data, as well as the communication of data between ALVINESA NATURAL INGREDIENTS S.A.U. companies, is the legal obligation established in articles 10 and 13 of Law 2/2023, of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption, to have these internal information systems (article 6.1.c GDPR).

Retention period

The data provided through the complaint or communication will be retained for the time necessary to carry out the necessary activities to investigate the facts and, where appropriate, to apply the contractual, disciplinary or judicial measures deemed appropriate. Likewise, you are informed that ALVINESA NATURAL INGREDIENTS S.A.U. will keep the data duly blocked during the periods in which the complaints or actions carried out by the organisation may give rise to liabilities. In any case, three months after the data have been entered into the complaints channel, they must be deleted from the complaints system, unless the purpose of the retention is to leave evidence of the functioning of the model for the prevention of the commission of crimes by the legal entity. ALVINESA NATURAL INGREDIENTS S.A.U. guarantees that the reports that have not been followed up will only be recorded in an anonymised form and the obligation to block provided for in article 32 of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights does not apply.

Obligation or not to provide the data and consequences of not doing so

If the complainant refuses to provide his/her data, ALVINESA NATURAL INGREDIENTS S.A.U. will not be able to process the complaint.

The information marked with an asterisk must be filled in. If you do not complete them, it will not be possible to submit the incident and, therefore, it will not be possible to process it.

You declare that the data provided in the form are true, being the only responsible of the false or inaccurate data provided and of the damages caused to ALVINESA NATURAL INGREDIENTS S.A.U. and to third parties, for the false information provided.

If you do not inform us to the contrary, we will understand that your data have not been modified, and you undertake to notify us of any change that may occur in them.

Are there any plans to transfer your data internationally?

No international transfers have been carried out or are planned. Otherwise, ALVINESA NATURAL INGREDIENTS S.A.U. will notify the interested parties of this transfer.

To which recipients will your data be communicated?

The recipients of the data will be, in addition to those required by law (Public Bodies, State Security Forces and Corps as well as Judges and Courts...), only the professional companies that provide services for ALVINESA NATURAL INGREDIENTS S.A.U. for the resolution of the complaint: law firms, etc. with which ALVINESA NATURAL INGREDIENTS S.A.U. subscribes a data processor contract in accordance with the terms of Regulation (EU) 2016/679 of 27 April 2016 and Organic Law 3/2018 of 5 December on the protection of personal data and guarantee of digital rights.

What are your rights when you provide your data?

You have the right to:

●Obtain confirmation as to whether ALVINESA NATURAL INGREDIENTS S.A.U. is processing personal data concerning you.

●Access to your personal data.

●Request the rectification of inaccurate data.

●Request their deletion when, among other reasons, the data are no longer necessary for the purposes for which they were collected.

In certain circumstances, you may request that we restrict the processing of your data, in which case we will only retain it for the purpose of pursuing or defending claims.

In certain circumstances and for reasons related to your situation, you may object to the processing of your data. ALVINESA NATURAL INGREDIENTS S.A.U. will stop processing the data, except for compelling legitimate reasons, or the exercise or defence of possible claims.

●To request the portability of the data.

●To withdraw the consents provided at any time, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.

●Claim before the Control authority of the data referring to your person included in our files, or in those of the professional companies that provide services for ALVINESA NATURAL INGREDIENTS S.A.U., under the terms established in the General Data Protection Regulation (Regulation (EU) 2016/679) and Organic Law 3/2018, of 5 December, on the protection of personal data and guarantee of digital rights.

How can you exercise your rights?

You may address a written request by post to ALVINESA NATURAL INGREDIENTS S.A.U., with address at Ctra. Valdepeñas Km. 4,850 Pol. Ind. El Campillo, 13250 Daimiel, Ciudad Real (Spain); or by e-mail to: [email protected], indicating the corresponding request and accompanied by a copy of your ID card or document proving your identity.

Please note that there may be legal obligations that we must comply with and that force us to refuse your requests or to keep certain information.

Finally, we inform you that you may contact the Spanish Data Protection Agency and other competent public bodies for any claim arising from the processing of your personal data.

We remind you that, if you provide us with data relating to another natural person, you must, prior to their inclusion, inform them of the points contained in this clause.

Are your data safe in Alvinesa Natural Ingredients S.A.U.?

ALVINESA NATURAL INGREDIENTS S.A.U., undertakes to comply with its obligation of secrecy of personal data and its duty to conserve and safeguard them by means of technical and organisational security measures that guarantee their security, prevent their alteration, loss, deterioration, processing or unauthorised access and the possible risks to which they may be exposed under the terms established in the General Data Protection Regulation (Regulation (EU) 2016/679) and Organic Law 3/2018, of 5 December, on the protection of personal data and the guarantee of digital rights.

Duration and modification of the Privacy Policy.

The party responsible for the website reserves the right to modify, in whole or in part, this Privacy Policy, publishing the changes on the website. Likewise, it may, without prior notice, make the modifications it deems appropriate, being able to change, delete or add both the contents and services it provides, and the way in which they are presented or located. Consequently, the general conditions/policies that are published at the time the User accesses the website shall be understood to be in force, and he/she should read them periodically.

Regardless of the above, the person responsible for the website may terminate, suspend or interrupt, at any time without prior notice, access to the contents of the website, without the User being able to claim any compensation whatsoever.

DATA PROTECTION INFORMATION: In compliance with the legal duty of information established in article 13 of Regulation (EU) 2016/679, in article 11 of Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights, and in Law 2/2023 of 20 February, regulating the protection of persons reporting regulatory infringements and the fight against corruption, you are provided with the following information relating to personal data:

INFORMATION CLAUSE

ALVINESA NATURAL INGREDIENTS S.A. (hereinafter "Alvinesa"), as Controller, informs the person concerned that the personal data included in it will be incorporated into a database of its ownership and will be treated in order to respond to enquiries and complaints made through the same, decide on their admission under the management model for the prevention of criminal risks, study and investigate the files and take appropriate action for this purpose.

- Check whether you expressly authorise the recording of Statements and Minutes for the appropriate internal investigation, pursuant to art. 18 C.E. and Law 1/1982 of 5 May, on the right to honour and one's own image. YES □ NO □

You can contact the Alvinesa at the following e-mail address: [email protected]

The information provided will be intended for members of the Compliance Committee or Criminal Alvinesa and other persons or entities, whose collaboration is necessary in the context of an investigation, or to audit the operation of the Ethical Channel, as set out in the Ethical Code, available to interested parties in the company. In any case, any person or entity would be subject to the obligation of confidentiality. Likewise, no data shall be communicated to any third party without the consent or information of the interested party, under the terms established in the legislation in force.

The facts and other information relating to the complaint will be communicated to the person being reported in the time and manner established by law. This communication to the reported party may exceptionally be delayed, if this is agreed by the Regulatory or Criminal Compliance Committee, when there are well-founded and objective suspicions that the communication to the reported party could compromise the investigation or there is a risk of destruction of evidence.

You are advised that the data collected may be transferred to the administrative or judicial authorities, when so requested, because of any procedure derived from the object of the complaint made, as well as to the persons involved in judicial or administrative proceedings initiated because of the investigation.

You are also informed that Alvinesa takes appropriate security measures to ensure the security, confidentiality, integrity and prevent unauthorized access to the data provided.

The legal basis that legitimizes the processing of personal data, as well as the communication of data between Alvinesa companies, is the legal obligation provided for in Articles 10 and 13 of Law 2/2023 of 20 February, regulating the protection of persons who report regulatory violations and fight against corruption, to have these internal information systems (Article 6.1.c GDPR).

The data provided through the complaint or communication will be retained for the time necessary to carry out the necessary fact-finding activities and, where appropriate, to apply the contractual, disciplinary or judicial measures deemed appropriate. You are also informed that Alvinesa will keep the data properly blocked during the periods in which complaints or actions carried out by the organization could result in liability. In any case, after three months from the introduction of the data in the complaints channel, shall be deleted from the complaints system, unless the purpose of conservation is to leave evidence of the operation of the model of prevention of the commission of crimes by the legal person. Alvinesa guarantees that the reports that have not been followed up will only be recorded in an anonymised form and the obligation to block them provided for in Article 32 of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights does not apply.

By clicking on “I accept”, you agree to the processing of your data in the terms set out above and certify that the personal data provided are true, accurate, complete and up to date. Any changes to your personal data should be brought to the attention of Alvinesa as soon as possible.

Please note that you have the right to exercise, where appropriate, your rights of access, opposition, rectification, deletion, limitation of processing, portability and not be subject to automated individual decisions by contacting the email address [email protected] or by mail addressed to Alvinesa Natural Ingredients S.A.U., Ctra. Valdepeñas Km. 4.850 Pol. Ind. El Campillo, 13250 Daimiel, Ciudad Real (Spain)

For further information regarding the exercise of your rights, please see our privacy policy on our website www.alvinesa.com