CLIENTS AND POTENTIAL CLIENTS

TYPE OF DATA

PURPOSE AND LEGAL BASIS

The following:

• Identification data: name, surname, passport number.

• Contact data: e-mail, telephone number.

1. Performance of a contract between you and/or the company you represent and HBX GROUP or application of pre-contractual measures:

• Manage the contractual relationship with you and ensure the provision of the contracted products and services, which includes both the management of services offered by HBX GROUP, as well as the service quality, billing, collection and withdrawal of the same.

• Manage the commercial relationship with potential clients, attending to requests for information on products and services offered by HBX GROUP.

• Manage and process any legal claims, out-of-court claims and insurance claims received by HBX GROUP in relation to you.

b) Legitimate interests of HBX GROUP:

• Carry out commercial communications related to products and services similar to those contracted by you. In this case, the legitimate interest of HBX GROUP would be to carry out direct marketing activities aimed at its clients, in accordance with Recital 47 of the General Data Protection Regulation.

• Conduct surveys and market studies to know the quality of our products or services and the preference of our clients. The legitimate interest of HBX GROUP is to improve the commercial offer and experience to its clients.

PROVIDERS AND POTENTIAL PROVIDERS

TYPE OF DATA

PURPOSE AND LEGAL BASIS

The following:

• Identification data: name, surname, passport number.

• Contact data: e-mail, telephone number.

Performance of a contract between you and HBX GROUP or application of pre-contractual measures:

• Manage the commercial relationship with potential providers, attending to requests for information.

• Formalize the contractual relationship, which includes the contracting process and signature of the contracts.

• Manage the contractual relationship with the providers of HBX GROUP, which includes tracking the relationship and payment to them.

CANDIDATES

TYPE OF DATA

PURPOSE AND LEGAL BASIS

Those data requested in the Website and, among others:

• Identification data: name, surname, age, Curriculum Vitae and/or cover letter.

• Contact data: email, telephone number, address. 

• Additional data that we can get from the recruiting process.

Performance of a contract between you and HBX GROUP or application of pre-contractual measures:

• Manage the personnel selection process of HBX GROUP, which will include the revision of the Curriculum Vitae and the conduct of personal interviews.

• Formalize the contractual relationship, which will include the contracting process and signature of contracts and labor agreements.

With your consent: 

• We will keep your profile active as a candidate during a 2 years period for futures job offers. 

The data generated during the selection processes in which you participate shall also be processed, which implies the possibility of performing an analysis of your personal profile in order to assess your suitability for the corresponding vacancy.

Among such additional data, the following may be processed data published on social networks whose privacy settings are not restricted to third parties and/or data published on the Internet.

HBX GROUP CORPORATE CONTACTS

TYPE OF DATA

PURPOSE AND LEGAL BASIS

Personal data that you provide to us in your contact by email, such as:

• Identification data: name, surname.

• Contact data: email, telephone number.

• Data related to the relationship established with HBX GROUP.

The legitimate interest of HBX GROUP derived from the contact for corporate purposes with the data subjects, which is expressly recognized by the privacy regulations, where applicable.

The purpose is:

• To maintain relations of any kind with the company, entity or organization for which you work or collaborate, or with you if you are an independent professional, who contact through the Website or any form, communication channel or email box. Even through the delivery of business cards to HBX GROUP staff.  

GENERAL CONTACT

TYPE OF DATA

PURPOSE AND LEGAL BASIS

Personal data that you provide to us in your contact by email.

Legitimate interest on answering your question and/or claim. To deal with requests, queries or complaints through the sections and contact forms on the Website or through other channels such as email for general information about the Website or call centers.

WEB / PLATFORM USERS

TYPE OF DATA

PURPOSE AND LEGAL BASIS

• Navigation data

• Technical data

• IP address

The processing of your personal data is legitimized by the express consent you give us through the cookie banner made available by HBX GROUP.

You may withdraw your consent at any time in accordance with the information provided in our Cookies Policy.

However, HBX GROUP may process information obtained through cookies or similar technologies without your consent as long as it is anonymized or aggregated information that does not contain any attribute that can identify directly or indirectly.

The purpose is:

• To personalize and segment the content of the Website through the use of cookies or similar technologies when these are consented to by the user through the corresponding banner.

KNOW YOUR BUSINESS AND COMPLIANCE

TYPE OF DATA

PURPOSE AND LEGAL BASIS

We obtain the following data directly from you:

• Identification data: name, surname, passport number.

• Contact data: e-mail, telephone number.

• Those personal data that you provide us and that are generated in the relationship.

We obtain the following data from third parties:

• Data used to identify individuals, such as names, identification documents.

• Information about business activities, such as affiliation with and ownership of businesses, employment/role details.

• When authorised by law, information about court judgments and criminal activity, such as details of offences and court dispositions.

• When authorised by law, sanctions lists, watch lists and lists of politically exposed persons, including your presence on such lists and you (or your family members’ or business associates’) affiliations with government officials.

• Information from public media, such as information in published news sources that may reveal connections to suspected criminal activity.

• Family circumstances information (e.g. your marital status and dependents) if you are a Politically Exposed Person or a close associate of a Politically Exposed Person.

• Professional and personal affiliations (for example, organisations and individuals that you may be associated with in your professional or personal capacity).

The processing of your personal data is legitimized by HBX GROUP’s legitimate interest when HBX GROUP is interested in concluding a deal with a third party as follows.

The purpose of this processing is to screen individuals to prevent and detect fraud, terrorism, money laundering, bribery and corruption, and other crimes by conducting checks against databases like WorldCompliance and Accuity provided by LexisNexis or other similar service providers.

SOCIAL MEDIA USERS

TYPE OF DATA

PURPOSE AND LEGAL BASIS

Those personal data that allow us the privacy policy of the social network in which you have an account / user profile, as well as the privacy settings you have as a user of that social network. This data depends on your own privacy settings of the social network and the privacy policy of that social network.

HBX GROUP has active profiles in different social networks, the following personal data processing are applicable to persons who become HBX GROUP stakeholders by being a member, following or being part of such profiles.

Performance of the obligations arising from your status as a registered user of the social network and the conditions of use of such social network:

• Interaction of your profile in the corresponding social network with HBX GROUP, including responding to queries, comments posted on public profiles.

APPLICABLE TO ALL DATA SUBJECTS

TYPE OF DATA

PURPOSE AND LEGAL BASIS

Those personal data that you provide us and that are generated in the relationship.

Fulfilment of our civil, commercial, tax, accounting and legal obligations related to compliance with personal data protection regulations, among others that may be applicable.

RECIPIENT

PURPOSE

LEGAL BASIS

Public administrations;

Courts and tribunals;

Law enforcement agencies

For the fulfilment of the legal obligations to which HBX GROUP is subject for the development of its activity, and in the cases provided by law, including the obtaining of subsidies and public aid.

Fulfil a legal obligation.

To comply with the legal obligations of account auditing to which HBX GROUP is subject due to its activity.

Fulfil a legal obligation.

To screen individuals to prevent and detect fraud, terrorism, money laundering, bribery and corruption, and other crimes by conducting checks against databases like WorldCompliance and Accuity provided by LexisNexis or other similar service providers.

The legitimate interest of HBX GROUP in concluding a deal with a third party.

We may communicate the data to the other Group companies with the purpose of being able to offer the best service for you taking into consideration your allergies and/or special needs and other administrative purposes.

The legitimate interest of HBX GROUP recognized by the applicable regulations on data protection.

Analysis and execution of commercial operations in which HBX GROUP may be involved due to structural modifications or transfer of business.

Legal empowerment by article 21 of the Organic Law on Data Protection and Guarantee of Digital Rights.