1. Data controller
In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, the General Data Protection Regulation (GDPR), and Spanish Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), the following information is provided regarding the processing of personal data in connection with the website www.avancem.es.
The data controller is:
- Company name: Advance Engineering Mademan, S.L.
- Trading name: AVANCEM Engineering
- Tax identification number (NIF): B02797355
- Registered address: Polígono Industrial La Cerrada II, 25, 39600 Maliaño (Camargo), Cantabria, España.
- Email: avancem@avancem.es
- Telephone: +34 942 260 211
- Website: https://www.avancem.es
The company will hereinafter be referred to as “AVANCEM”.
For any queries relating to the processing of personal data or the exercise of rights recognised by law, data subjects may contact AVANCEM using the contact details provided.
2. Scope
This Privacy Policy governs the processing of personal data arising from visits to and use of AVANCEM’s website, as well as communications that users establish with the company through the published contact channels.
The Website is primarily informational and corporate in nature. Its purpose is to present AVANCEM’s capabilities, projects, activities and news, and to facilitate contact with its various departments.
The Website currently has no integrated contact forms, registration systems or user accounts.
Enquiries received through the published contact channels are managed through corporate email inboxes. Contacts received are not automatically added to a CRM system.
This policy concerns processing activities associated with the Website, without prejudice to any specific data protection information that may be provided in the context of contractual, employment or commercial relationships, or other company activities.
3. Categories of personal data
Depending on the user’s interaction with the Website, AVANCEM may process the following categories of data:
a) Identification and contact data
First name and surname, email address, telephone number, professional role, company or organisation, and other data that the data subject voluntarily provides when communicating with AVANCEM.
b) Data relating to requests and communications
Information included in technical enquiries, commercial requests, requests for quotations, collaboration proposals or other communications addressed to the company.
These data may include information about projects, technical requirements, professional needs or attachments, insofar as the data subject chooses to provide them.
c) Technical browsing and connection data
Data that may be recorded when accessing the Website for technical, operational or security reasons, such as IP address, date and time of access, resources requested, browser type and technical information about the device.
The actual processing of these data will depend on the server configuration and the technological services used.
AVANCEM does not request special categories of personal data through the Website. Users are advised not to include sensitive personal information that is unnecessary for handling their requests.
4. Purposes of processing
Personal data may be processed for the following purposes:
4.1. Handling enquiries and requests
Receiving, managing and responding to communications sent to the engineering, administration or sales departments.
4.2. Managing professional and commercial relationships
Handling requests for information, assessing potential projects, preparing technical or commercial proposals and carrying out the relevant pre-contractual steps.
4.3. Communications relating to existing requests
Maintaining the contact necessary to follow up on enquiries, proposals, collaborations or professional relationships initiated by data subjects.
4.4. Security and operation of the Website
Ensuring technical operation, detecting incidents, preventing unauthorised access and protecting AVANCEM’s digital systems and infrastructure.
4.5. Compliance with legal obligations
Complying with applicable regulatory obligations and, where appropriate, handling requests from competent authorities or the exercise and defence of rights and legal claims.
Data obtained through the Website will not be used for purposes incompatible with those for which they were collected, unless there is a legal basis permitting such use and the information required by law is provided.
Sending an enquiry does not result in automatic subscription to commercial newsletters or authorisation to receive advertising campaigns.
5. Legal basis for processing
The applicable legal bases will depend on the specific purpose of the processing.
a) Legitimate interests — Article 6(1)(f) GDPR
For handling professional communications, managing business contact relationships and protecting the security and proper operation of the Website, provided that the rights and freedoms of the individuals concerned are not overridden by those interests.
In professional relationships between businesses, Article 19 of Spanish Organic Law 3/2018 may apply, under the conditions laid down in that provision, to the processing of professional contact data and the management of relationships with legal persons.
b) Taking pre-contractual steps or performance of a contract — Article 6(1)(b) GDPR
Where processing is necessary to handle requests made by an individual interested in contracting services, or to manage a contractual relationship to which that individual is a party.
c) Compliance with legal obligations — Article 6(1)(c) GDPR
Where processing data is necessary to comply with legally enforceable obligations.
d) Consent — Article 6(1)(a) GDPR
Where a specific processing activity requires the data subject’s consent, it will be requested specifically and may be withdrawn at any time, without affecting the lawfulness of processing carried out previously.
Any electronic commercial communications must also comply with the conditions established in Spanish legislation on information society services.
6. Source of data
Personal data processed in the context of communications made through the Website will mainly originate from information provided directly by data subjects.
When an individual contacts AVANCEM by email, the data communicated are received and managed through corporate inboxes by authorised personnel.
Technical connection data may be generated automatically when accessing the Website, depending on the systems used for its hosting and operation.
7. Data retention
Personal data will be retained for as long as necessary to fulfil the purposes for which they were collected and, where applicable, for the periods required by applicable legislation.
Communications and documents relating to commercial enquiries, quotations, contracts, projects and professional relationships may be retained for as long as they are needed for their management, technical and contractual follow-up, compliance with legal obligations, or the establishment, exercise and defence of legal claims.
Personal data included in such communications will be subject to the applicable retention and erasure criteria, taking into account the purpose of the processing and the corresponding obligations.
Enquiries that do not lead to a professional relationship will be retained only for as long as necessary to handle them and carry out reasonable follow-up.
When personal data are no longer necessary and there is no legal obligation or other legitimate reason to retain them, they will be erased or, where required by law, blocked.
8. Recipients and service providers
As a general rule, personal data will be processed by AVANCEM and by authorised personnel who need access to them to fulfil the purposes described.
Communications received through the addresses published on the Website are managed through corporate email and are not automatically added to a CRM.
For the operation of the Website and the management of communications, AVANCEM may use technology providers offering services such as:
- Website hosting and maintenance.
- Email and business communications.
- IT support and system security.
Where these providers process personal data on behalf of AVANCEM, they must act in accordance with the obligations and safeguards required by the GDPR.
AVANCEM does not disclose data received through its contact channels to third parties for the purpose of marketing databases.
Data may also be disclosed to public administrations, judicial authorities or other bodies where a legal obligation or a legally valid ground justifies doing so.
9. International data transfers
The use of certain technological services may involve personal data being processed or accessed from countries outside the European Economic Area.
The existence of external technology providers does not necessarily mean that international data transfers take place.
Where international transfers are made, AVANCEM must ensure that they comply with the requirements of Chapter V of the GDPR, using, as appropriate, European Commission adequacy decisions or other mechanisms and safeguards provided for by law.
Information about the providers actually involved in such transfers, the destination countries and the applicable safeguards must be kept up to date and made available to data subjects.
10. Data subjects’ rights
Data subjects may exercise the following rights under the conditions established in applicable legislation:
- Access: to know whether their personal data are being processed and obtain information about that processing.
- Rectification: to request the correction of inaccurate or incomplete data.
- Erasure: to request the deletion of their data where the circumstances provided for by law apply.
- Objection: to object to certain processing activities, including those based on legitimate interests, where applicable.
- Restriction of processing: to request that processing be restricted in the cases provided for by law.
- Data portability: to receive their data in a structured, commonly used and machine-readable format and, where applicable, transmit them to another controller.
- Withdrawal of consent: to withdraw consent given for processing at any time, where consent is its legal basis.
- Not to be subject to solely automated decisions: in the cases provided for by the GDPR.
To exercise these rights, the data subject may contact:
They may also submit their request in writing to the address indicated in section 1.
The request must enable the data subject to be identified and specify the right they wish to exercise.
Where there are reasonable doubts about their identity, AVANCEM may request proportionate additional information to verify it.
Requests will be handled within the period established by law, generally one month from receipt, without prejudice to the extensions permitted by legislation.
If a data subject considers that their rights have not been duly addressed, they may lodge a complaint with the Agencia Española de Protección de Datos (AEPD):
11. Voluntary provision of data
Browsing the informational pages of the Website does not require users to voluntarily provide their identification data.
When an individual communicates with AVANCEM by email or through another available channel, they should provide only the data necessary to identify their request and enable it to be handled.
The absence of certain contact details or essential information about the request may prevent AVANCEM from responding to or properly managing the communication.
12. Information security
AVANCEM will apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration, improper disclosure or other risks to their confidentiality, integrity and availability.
These measures will be established taking into account the nature of the data processed, the context of the processing and the associated risks.
However, no information transmission or storage system can guarantee absolute security.
13. Third-party services and links
The Website may include links to the websites of other companies, scientific organisations, institutions and external platforms.
These services may include Google Maps, to view the location of the facilities, and LinkedIn, to access AVANCEM’s corporate profile.
When accessing these external platforms, personal data processed by their respective operators will be governed by their own privacy policies.
The Website also uses Google Fonts typography resources. When these resources are loaded from external servers, certain technical data, such as the visitor’s IP address, may be transmitted.
Specific information relating to cookies and similar technologies is set out in the Cookie Policy.
14. Automated decision-making and profiling
The Website is not designed to make solely automated decisions that produce legal effects concerning its visitors or similarly significantly affect them.
Nor is it intended to function as a platform for advertising profiling based on browsing behaviour.
If functionalities involving different processing activities are introduced in the future, the corresponding information must be updated before they are used.
15. Changes to the Privacy Policy
AVANCEM may update this Privacy Policy to reflect changes in legislation, organisation, technology or the data processing activities carried out.
The current version will be available on the Website, together with its date of last update.
Where changes substantially affect processing activities and legislation requires it, the corresponding additional information will be provided to data subjects.