Privacy Policy

Privacy Policy and Personal Data Protection of LORTEK Website

1. Data controller

LORTEK, hereinafter the “Data Controller”

VAT no.: ES-F20759072

Address: Arranomendi kalea, 4A

City / town / village: 20240 Ordizia (Gipuzkoa)

Telephone: +34 943882303

E-mail: lortek@lortek.es

2. Applicable Law

Basic personal data protection regulations applicable to data processing by LORTEK include:

1. EU Regulation 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of individuals with regard to personal data processing and free movement of such data (“GDPR”).
2. Organic Law 3/2018 of 5th December, on Protection of Personal Data and Guarantee of Digital Rights (Spanish acronym, “LOPDGDD”).
3. Their respective supplementing and development regulations.

3. Websites and social network channels

The official LORTEK website is found at www.lortek.es. LORTEK's main official social media channels are:

• Twitter: https://twitter.com/lortek
• LinkedIn: https://es.linkedin.com/company/lortek
• YouTube: https://youtube.com/@LortekSCoop

For the purposes of this Privacy Policy, the official LORTEK website and the official LORTEK channels on social networks will be referred to all together as "the website", unless otherwise specified.

4. Purposes and legal basis

To comply with current Personal Data Protection regulations, users are informed that any personal data provided by them through any means found on the website or official channels on LORTEK's social networks (via e-mail, forms, etc.), or derived from their use, may be incorporated into LORTEK's data processing systems.

The purposes of data processing that may take place on LORTEK website are:

1. providing a tool for contact, consultation, and communication between LORTEK and Data Subjects, in response to applications and requests (such as contact forms or CVs).

   Main lawful basis: Consent from Data Subjects (GDPR art. 6.1.a), when they provide their data for these purposes.

2. Provision of services as a research and development technology centre; manage and analyse the use of the website; send informative and professional communications related to our services; inform, organize and disseminate activities and initiatives launched by LORTEK, or in which LORTEK participates.

Main lawful basis: Legitimate interests of the Data Controller (GDPR art. 6.1.f)

5. Storage period

Personal data provided will be retained for the time necessary to comply with the purpose for which they were compiled; to determine any possible responsibilities that might arise from the purpose; or for the period that the applicable regulations establish in each case. After such period they will be deleted, and the necessary security measures will be implemented to guarantee their confidentiality.

6. Duty of secrecy

LORTEK is committed to uphold the privacy and protection of users’ data. The processing of your personal data will be carried out confidentially, and in compliance with these regulations. People working at LORTEK and who may access personal data, are trained in personal data protection and have signed confidentiality and professional duty of secrecy agreements.

7. Personal data collection.

The Data Controller will not ask you to provide personal details to access the website; however, to complete forms on the website (contact forms, CV submission, etc.), users are required to provide personal data mainly related to identification and contact details.

The user provides his or her personal data freely and voluntarily. LORTEK will not request any personal information other than that necessary to carry out the service requested.

Any user who sends/includes any type of content (data, documents, texts, videos, audio, photographs, charts, messages or other material) declares and guarantees to do so in such a way as to comply with the conditions expressed herein and with current legislation. Any user who includes third parties’ personal data shall declare that they have their express consent to process such data.

The user is the only person responsible for the truthfulness, accuracy and lawful processing of the data introduced, holding LORTEK harmless from any liability in this respect. In any case, users guarantee and are responsible for the accuracy, validity and authenticity of the personal data provided, and undertake to keep them up to date. Failure to complete or provide incorrect information in fields indicated as compulsory on website forms may result in the Data Controller not being able to attend to the user's request.

The Data Controller will collect personal data in an appropriate manner, relevant to the purposes, utilities, services and/or features included on the website, as well as in a specific, explicit, and legitimate way. Therefore, the means used will not under any circumstances be fraudulent, unfair or illegal, or in any way jeopardise the legitimate rights of users.

Submitting information through this website automatically implies express authorisation for data processing described in this privacy policy and in the general conditions of the website.

8. Specific data processing:

1. Job applicants at LORTEK

   A user submitting a curriculum vitae, putting forward a candidacy for a job with LORTEK through the website, forms, e-mail or similar systems, gives his or her express consent for his or her data to be included in data processing called "CV and Recruitment”.

   Your data may be used for the purpose allowing you to take part in future recruitment processes at LORTEK and if appropriate, may be transferred to other technology and research centres that are members of the “Basque Research and Technology Alliance (BRTA)" for the same purpose, allowing you to take part in their recruitment processes.

   Likewise, your data may be transferred to external companies hired by LORTEK to carry out personnel recruitment processes.

2. Registers and subscriptions

   In the case of subscribing to newsletters or similar services which involve personal data processing, users may request the cancellation of such services at any time by sending a request to the email address lortek@lortek.es or using any other means that LORTEK may provide for this purpose, such as the "Unsubscribe” button, located at the end of the newsletters.

3. Children’s personal data

   The Data Controller does not specifically aim its services at minors. In the event of any of our services specifically aimed at minors, the Data Controller shall request the consent of parents or guardians to collect personal data or, if appropriate, for processing of such data.

   The Data Controller recommends users consult the different materials developed by the supervisory authorities in relation to personal data protection of children and young people.

   This information (recommendations, user manuals on new technologies, educational videos, etc.) is available on the websites of the Basque Data Protection Agency, http://www.avpd.euskadi.eus/s04-5249/es/contenidos/informacion/publicaciones_avpd/es_def/index.shtml#tab_item2063 and the Spanish Data Protection Agency, http://tudecideseninternet.es/aepd/

9. Link to social networks and web channels

This website may offer links to social networks and external websites and channels, such as Twitter or YouTube, among others. LORTEK assumes no responsibility in relation to the linked sites. Any user accessing social networks and external websites and channels related to LORTEK, from links located on this website or in any other way, is hereby previously and expressly informed that the conditions of use, privacy policies, cookies policies and any other terms and conditions or regulations depend on the bodies responsible for such social networks, websites and channels, and never on LORTEK.

10. LORTEK present on social networks

LORTEK has profiles in social networks with the main purpose of disseminating its aims and activities. Any publication offered through these channels is for guidance only.

By registering on LORTEK profiles with their social network profile, users give their express consent to LORTEK to process their personal data in accordance with this Privacy Policy.

Any information and personal data voluntarily provided by the user through LORTEK social networks may be processed for the purpose of contacting the user, and dealing with any queries and requests made by him/her, sending information and professional communications, managing events, invitations and similar activities, collecting the user's opinion or feedback about LORTEK and its publications, and in general, managing the presence of LORTEK on social networks.

Users are informed that any information and contents (data, texts, videos, audio, photographs, charts, comments, messages or other material) posted by them on LORTEK's social networks (including, if appropriate, personal data) may be publicly available to other users of the social networks and may be freely visible, commented on and shared by visitors, under the terms and conditions set by each social network.

With the user profile settings of each social network, the user can configure any information he/she wants to make public in each case, see any permissions he/she has granted, delete or deactivate them, and manage his/her posts at his/her own discretion and as per the rules of use of each social network.

A user who posts content on social media will be ultimately responsible to ensure that his/her post complies with current legislation, rules of use and privacy policies established by the social network and LORTEK. LORTEK does not assume any liability for users’ postings on social media. LORTEK will unilaterally and without prior notice remove any content that it considers to be in breach of current legislation, the rules of use and privacy policies, or deemed inappropriate.

LORTEK follows profiles on Twitter, YouTube and other social networks, without implying any kind of relationship with them.

LORTEK's channels on Twitter, YouTube and other social networks are followed by other users of these networks, without implying any kind of relationship with them.

LORTEK reserves the right not to respond to messages or comments received through these channels. LORTEK may at any time and without prior notice modify or remove any posts made on its social networks.

By becoming a follower or clicking "Like" on social networks, you consent: 1) to the processing of your personal data in the relevant social network environment, in accordance with its privacy policies; 2) to grant LORTEK access to the data contained in your contact list and publications; and 3) to news posted appearing in your notices and notifications.

If a user wishes to stop following official channels on LORTEK social networks, he/she may do so using the tools provided for that purpose by each social network.

11. Security measures

LORTEK will process personal data contained in its data processing, applying the technical and organizational measures necessary to guarantee their security and prevent their alteration, loss, unauthorised processing or access, taking into account the state of the art, the nature of the data stored and the risks to which they are exposed, whether these are the result of human action or physical or natural environment, and according to the applicable law related to security measures for personal data processing. However, users are informed that IT security measures are not impregnable, and are not safe from possible illegal and undue interference, which would not be the responsibility of the Data Controller.

In order to guarantee the security and privacy of the user, LORTEK uses encryption technology based on Secure Sockets Layer (SSL) protocols, to ensure browsing is as safe as possible.

12. Security breaches

Users must immediately notify LORTEK of any incident, security breach, improper or unauthorized access detected in relation to their passwords, or any other circumstance that may jeopardize the security and confidentiality of data, or the correct operation of the website. Our main contact channels are: telephone number +34 943882303 and e-mail address lortek@lortek.es

13. Rights of data subjects

You may exercise your rights related to the protection of your personal data (access, rectification, deletion, limitation to processing, portability and objection), as well as withdraw any consents granted, or make any other request in this regard by writing to the Data Controller, LORTEK, at Arranomendi kalea, 4A, in 20240 Ordizia (Gipuzkoa), by phone on +34 943882303 or by e-mail to lortek@lortek.es.

Applications must be accompanied by a copy of a document proving the applicant's identity (ID card or similar). If the applicant is acting in his/her capacity as a legal representative, in addition to a copy of the document proving his/her identity, a document certifying such representation must be attached.

If you do not agree with the result of your applications or would like to file a complaint, please contact the following supervisory authority: Spanish Data Protection Agency www.aepd.es

14. Validity and modifications

The Data Controller reserves the right to amend this Privacy Policy at its own discretion, or as a result of changes in law or case law. These modifications will be valid from the moment of their publication on the website. Relationships with users will be governed by the rules established at the time of access to the website. For this reason, the Data Controller recommends you visit this Privacy Policy each time you connect to the website.

15. Jurisdiction

Any relationships established between LORTEK and the user will be governed by the provisions of the regulations in force regarding applicable law and competent jurisdiction. However, in cases where regulations allow the possibility of the parties submitting to a jurisdiction, LORTEK and the user expressly renouncing any other jurisdiction that may correspond to them, submit themselves to the Courts and Tribunals of Tolosa (Gipuzkoa).

LORTEK will pursue any breach of this Privacy Policy, as well as any improper use of the contents presented on this website, exercising any civil and criminal remedies it may have at its disposal, including those of an economic nature.