Privacy Policy

Introduction

Data privacy is important to us. At Werfen we recognize the importance of protecting your personal data and are committed to processing it responsibly and in compliance with the applicable laws.

This Privacy Policy is intended to describe how we, Leventon S.A.U (hereinafter “Werfen”, “we” or “us”), a Spanish company holding tax Identification number A08586265, with corporate address at Ronda Can Margarit 38, Pol.Ind. Can Margarit, 08635 Sant Esteve Sesrovires, Barcelona and registered with the Commercial Registry of Barcelona under volume 22.669, folio 156 and sheet B-41.384, process your personal identifiable information (“PII”) in our capacity as data controller, determining the means and/or purposes of their processing.

We may update this Privacy Policy from time to time. When doing so, changes will be effective immediately upon posting the revised Privacy Policy on the Site. As a result, we recommend that you check this Privacy Policy on a regular basis.

This Privacy Policy was last updated on 06/28/2021.

Scope of our Privacy Policy

Our Privacy Policy applies to all PII we collect, use, share or otherwise process through our business activities, both online and offline, of all registered users, visitors and subscribers to our websites, and all customers, suppliers, collaborators and other stakeholders who provide information during their routine interactions and activities with us (throughout this document, we will refer to “Sites” when you interact or use our websites and to “Services” when you enter into any contractual relationship with us).

Our Sites make use of cookies. For more information on this subject, please consult our Cookies Policy. Further, when using our Sites or Services, please read our Terms of Service.

Please note that:

We may also provide additional or more specific information on the collection or use of PII related to a specific product or service in the relevant product’s or service’s privacy policy.
We may act only as a “processor” (not as a “controller”) with respect to the PII processed for the rendering of some Services. This means that we handle the PII solely on behalf of the relevant stakeholder within the framework of the Services, unless legally required to do otherwise.
Our Sites may contain hyperlinks to third-party websites which are not controlled by Werfen and which are not covered by this Privacy Policy. We have no responsibility or liability for the content and activities of these third-party websites. As these third parties may collect your PII, we suggest that you consult the privacy policies of these third-party websites to learn more about their use of your PII.
All Werfen companies have their own Privacy Policy. Even though there should be little differences in how we collect, use or disclose your PII from country to country, we will inform you about any specific processing activities of your PII that take place in your country, please refer to them for further information.

Information that you give us

As an individual, we gather your PII as explained below:

Information we automatically collect:

Some PII may be collected automatically when you visit or use our Sites, such as information collected by cookies.

PII collected this way may include: Information about your IP address, type of browser, log information and performance and metric statistics to help improve and further develop our Sites.
Information you provide to us:

We may obtain your PII from you through our Sites (e.g., when you sign up for our newsletter, register on our Sites, make a comment or enquiry, subscribe to direct marketing of our products or services, etc.) or when you use the Services that we provide (e.g., when you buy a product from us, fill out a service satisfaction survey, etc.).

PII collected this way may include: Your name, surname, job title, postal and billing address, country, institution or company, postal code, e-mail, username, password, telephone number, CV, and/or information relating to your products and services (e.g., purchases and payment information, feedback, marketing preferences, events and trainings, contact information derived from interaction with our customer or technical service, etc.) and any other PII you voluntarily provide us directly.

How we use your information and legal reason for the processing

We process your PII for the purposes indicated below on the following legal grounds:

To meet our contractual obligations or to take steps to enter into a contract with you:
- As a Werfen customer, supplier, collaborator or stakeholder we use your PII for the fulfilment of our contractual obligations such as communications, processing of payments, products and/or services delivery and offering the necessary customer service with respect to your purchase/s. In the case of collaborators, we may also process PII to assess their suitability to distribute or promote Werfen’s products.
- To respond to your requests for information or support.
- To manage, operate and protect our Sites to make your experience safer and better when visiting us as well to carry out the relevant administrative and maintenance tasks of the Site.
- If you send us your CV, to evaluate the suitability of your profile with respect to the position requested. See the section “Receiving your CV” for further detail.
- For a business sale, merger, consolidation, change of control, transfer of substantial assets, reorganization, or due diligence in anticipation of such an event (e.g., if a company were to acquire Werfen, it may also acquire the PII we hold).
Because it furthers the legitimate interests of Werfen in business activities, such as the ones listed below, and because that handling does not unduly impact your interests, rights, and freedoms:
- To understand your needs, provide you with a better service and improve our existing products and services.
- To contact you, both electronically and non-electronically, to obtain your opinion about the quality of our services and/or products and examine your degree of satisfaction
- To protect the safety of our employees, visitors and property using a video surveillance system. See the section “Video surveillance at Werfen’s premises” for further detail.
- To keep you informed about our newest products and services as well as any event that may be of interest to you through our newsletter (this includes sending certain direct marketing). You may oppose to these communications at any time by unsubscribing our newsletter.
To meet legal compliance obligations, regulatory requirements and claims:
- We manage your PII as required by the applicable regulations (including administrative, tax, accounting and labor obligations).
- To establish, exercise or defend legal claims.
- Under certain circumstances where we believe that using or disclosing the PII is appropriate to protect the rights, safety, and property of Werfen or others (e.g., when required to make disclosures in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements).
We need your consent:
- To conduct some of our direct marketing activities (e.g., sending direct marketing if you have not entered into any contractual relationship with us), keep you informed about any event we participate in or when the law requires your explicit consent. If you do not wish to receive such marketing communications anymore, you will always have the opportunity to "opt out" by following the “unsubscribe instructions” provided in each of our direct marketing e-mails or by contacting us directly (please see our contact information at “how to contact us” section below).

We will not use your PII for any other purpose incompatible with the purposes listed above, unless it is authorized by you, or it is necessary for us to comply with a legal obligation, to resolve disputes and/or to prevent security issues or abuse.

How long does Werfen store your PII?

We will not retain your PII longer than is legally permitted and necessary for the related processing purposes (e.g., for as long as there is a Service relationship or you are using our Sites, or for as long as we have another purpose to do so). However, please bear in mind that the storage period depends on the type of PII, the purposes and the applicable law and therefore varies per use.

Once this time has expired, certain regulations oblige us to keep such data for a longer period, especially to deal with possible complaints or comply with legal obligations. During this time, we will keep your PII blocked only to comply with these purposes.

To whom we may share your PII

We share your PII with other organizations in the following limited circumstances:

Intra-group sharing:
- As a global company, your PII may be shared with affiliated companies world-wide and transferred to countries where we do business in accordance with this Privacy Policy. Between Werfen affiliates we only grant access to your PII on a need-to-know basis, necessary for the purposes for which such access is granted. Visit the section “Select country” of our website to find out who we are.
Third-party service providers:
- When we use trusted third-party service providers who work on our behalf, such as marketing agencies, software, data hosting and other IT service providers, payment processors, etc. These third-party service providers are required not to use your PII other than to provide the services requested by us or otherwise in accordance with our instructions.
Acquisitions:
- In connection with a corporate transaction, such as the sale of all or a portion of our business, a divestiture, merger, consolidation or an asset sale, the recipient company may acquire all or part of the PII collected by us and will assume the rights and obligations regarding your PII as described in this Privacy Policy. In the unlikely event of an insolvency, bankruptcy or receivership, your PII may also be transferred as a business asset, subject to applicable law.
Disclosures:
- We may disclose your PII if we believe in good faith that such disclosure is necessary for our legitimate interest or prudent considering our obligations under applicable law:
  - In response to a subpoena or similar investigative demand, a court order, or other request from a law enforcement or public administration.
  - To establish or exercise our legal right, to defend against legal claims or as otherwise required by law.
  - In connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
  - To protect and defend the rights, property or safety of Werfen, our employees, or others.
  - To investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy or any applicable Terms of Use.

We and our third-party service providers may have operations in several locations in the world. Consequently, we and our third-party service providers may transfer PII to, or access them from, countries outside your country of domicile.

We take steps to ensure your PII receive an adequate level of protection in the countries in which we process them. In case our processing is subject to any EU data protection regulation and your PII is transferred from the EU to a third-party service provider for processing in any country outside the EU that is not recognized as providing an adequate level of protection for PII, we provide for appropriate safeguards by EU Commission’s standard contractual clauses or by any other appropriate safeguard as foreseen under the applicable data protection regulations.

You may contact us in the “how to contact us” section for further information regarding the international transfer of PII.

Your rights

We offer the options below for exercising your rights and choices about how we use your PII. Many of these are subject to important limits or exceptions under applicable laws:

Request a copy of the PII we hold about you. Depending on the Site or the Services, you may review and update certain information by accessing yourself to the relevant Site or Services.
Ask that we restrict the way in which we use your PII.
Ask that we update the PII we hold about you or correct any PII that you think is incorrect or incomplete.
Ask that we delete PII that we hold about you (the “right to be forgotten”).
Withdraw your consent, at any time for the future, to our processing of your PII (to the extent such processing is based on the legal grounds of your consent).
Object to us processing of your PII.
Request your PII be transferred to you or another data controller (the “data portability” right).

You may contact us with any concerns or complaints regarding our privacy practices or to exercise any of the aforementioned rights using the details set out at “how to contact us” below.

For your protection, we will only implement requests with respect to PII after we have verified your identity to our satisfaction, taking into consideration the nature of your request.

Whenever, in your opinion, the processing of your PII involves an infringement of the legal requirements, or if you are unhappy with the way we have handled your PII or any privacy query or request that you have raised with us, you have the right to complain to your local data protection regulator. For further detail you can see the list of the different European Data Protection Authorities by clicking here.

How we protect your information

We value the trust you place in us and how important it is to protect and manage your PII.

We use commercially reasonable technical and organizational measures to protect your PII against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access and against all other unlawful forms of processing. The PII you provide us with is stored on computer systems located in controlled facilities which can only be accessed by a limited number of persons who have a need to know in order to carry out their tasks and any services requested by you.

Should, despite of our security measures, a security breach occur that is likely to result in a risk to your PII, we will inform the relevant affected parties, as well as relevant authorities when required by applicable data protection law as soon as reasonably possible.

Children

Our Sites or Services are not directed towards children and we request that children below the age of 18 not to provide us with their PII. We do not knowingly collect or solicit PII from anyone under the age of 18. If you are under 18, please do not send any PII about yourself to us. If we learn that we have collected PII from a child under age 18, we will delete those PII as quickly as possible. If you believe that a child under 18 may have provided us PII, please contact us at using the details set out at “how to contact us” below to have the information deleted.

Receiving your CV

CVs can only be submitted to us by those applicants who wish to apply to any open position through our website or our profile in digital job’s platforms, being these the only channels for accepting your CV (we regret to inform you that we will not accept nor process CVs sent using other channels).

The disclosure of such PII to us is a necessary requirement for the execution of pre-contractual measures that you have requested, such as the evaluation of your CV, which is necessary to make you a participant in the selection process and the establishment of the possible contractual relationship with us.

Please note that your CV or any information that you may send us must not contain any PII relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometrics uniquely identifying you, or data relating to your health or sex life or sexual orientation since they are not necessary for the assessment of the position. Should such data be indicated in your CV, it will not be processed or stored, and the CV will be immediately deleted.

Your PII may be processed by authorized persons responsible to assess the profile of the applicants and to carry out the subsequent selection of personnel. They can belong to both the Human Resources department and the area or department deemed necessary to evaluate your professional profile and to achieve the completion of the selection procedure and any subsequent contractual relationship.

Social networks

We inform you that we may have presence in social networks. The processing of the PII we carry out of those who connect with us through our official social networks will be governed by this section, as well as by those conditions of use, privacy policies and access policies belonging to the social network in each case.
We will process your PII with the only purpose to correctly manage your presence in the social network, reserving the right to withdraw, without prior notice, any content considered inappropriate.
Please be aware that if you send any PII through the social network we will be exempt from any liability in relation to the protection of your PII.

Mobile apps
We may use mobile apps to interact with you. Since these mobile apps are not all alike, and thus the processing of your PII may vary, please refer to their specific privacy policy for further details of the processing of your PII.

How to contact us

As a global company, Werfen has appointed a person as the Data Protection Officer (DPO) to guarantee Werfen complies with all the legal requirements of the regulation regarding the protection of PII. In addition to that, with the aim of facilitating the resolution of any doubt or concern regarding data privacy, Werfen has also appointed a Local DPO (representative of the DPO) in every EU Werfen company.

The Werfen group’s DPO can be reached by e-mail at DPO@werfen.com or by mail at Werfen, S.A., Plaza Europa, 21-23, 08908, L’Hospitalet de Llobregat, Barcelona, Spain.

Your local DPO can be reached by e-mail at DPO-Leventon@werfen.com or by mail at Ronda Can Margarit 38, Pol.Ind. Can Margarit, 08635 Sant Esteve Sesrovires, Barcelona.

You can also find more information about our local DPOs and the corresponding Privacy Policy of the different Werfen Companies in the Section “Select Country” via the following link: https://www.werfen.com/en.