PRIVACY POLICY

• Introduction.

We have a high level of commitment to the privacy of individuals, so the protection of personal data is important to us.

We treat the data in accordance with the provisions of the EU Regulation 2016/679 General Data Protection Regulation, Organic Law 3/2018 on Personal Data Protection and Guarantee of Digital Rights and other regulations in force in this regard.

This Privacy Policy has been revised in May 2023 to comply with the duties of information and transparency of the website itself and the responsible party, to provide any type of interested party and not only the users of the website with the general terms of the responsible party in this matter. There may be variations until its next revision.

• Who is the data controller of your data?

Responsible: ICONIC SOLUTIONS BY MURCIA S.L.

NIF/CIF: B05569439

Address: Calle Central, 13, 1A - Torre Godoy, 30100, Murcia (MURCIA) Spain

E-mail: info@inbentus.com

• What is the origin and type of data we process?

The source of the information we process may be any of the following categories:

• Paper, electronic or digital forms.
• Communication and messaging systems: e-mail and messaging applications, telephone, etc.
• Other lawful sources and origins of information.

The different categories of data that we can potentially process depending on the type of data subject (user, customer, supplier, employee, etc.) and the nature of the data controller's activity and the different data processing operations are:

• Identification data, for example: name and surname.
• Identification codes or passwords, e.g., user name, employee code.
• Postal or electronic contact addresses, e.g. telephone, email, social media profile.
• Personal and professional characteristics data, for example: age, date of birth, qualifications, professional experience, curriculum.
• Economic, financial and insurance data; for example: bank details, credit card details, etc.
• Financial and non-financial payroll data and other information of an employment nature; for example: job title, payroll document, etc.
• Transaction data, e.g., goods and services provided and received.
• Other data and information necessary or implicit in the development of our activities, services and object.

MANDATORY OR OPTIONAL NATURE OF THE INFORMATION PROVIDED BY THE INTERESTED PARTY.

The interested party, by checking the corresponding boxes and entering data in the fields marked as mandatory (for example, with an asterisk) in the contact form or others, expressly and freely and unequivocally accept that their data are necessary to fulfill their request, by the responsible, being voluntary the inclusion of data in the remaining fields.

The interested party guarantees that the personal data provided to the data controller are truthful and undertakes to communicate any changes to them. The data requested through the website, marked as mandatory, are necessary for the provision of an optimal service to the person concerned. In the event that all the data is not provided, there is no guarantee that the information and services provided will be completely tailored to your needs.

• For what purposes do we process your personal data?

In general, the data are processed in order to successfully carry out the actions implicit in the normal development and management of the controller's activity. Although we can specify different processing purposes depending on the possible existing categories of interested parties:

• Customers and prospects: management and maintenance of commercial, pre-contractual and contractual relations; internal administration; financial management; advertising and marketing, customer service.
• Collaborators, creditors and suppliers: management and maintenance of commercial relations, internal administration and economic management.
• Employees: management, development and maintenance of the labor relationship, human resources management, communications, training activities, occupational risk prevention, registration of the working day and other purposes derived from legal obligations and development of labor relations.
• Candidates: management of resumes received, management of job offers and personnel selection.
• Web and social network users: user service and management of communications between the parties.
• The existing information of any other category of interested parties processed by the data controller will be done within the framework of its activity, in strict compliance with the applicable rules and under the general criteria of this Privacy Policy.

Other general purposes that the responsible party may implement are:

• Development of a commercial profile, with the aim of improving your experience by personalizing offers and communications. No individualized decisions will be made based on this profile and will act from legitimate interest.
• Control of monetary obligations. In the case of debtors with certain, due and enforceable payments pending, the responsible party may communicate this circumstance to credit solvency files, debtors' files, and debt management or collection services, among others, based on legitimate interest.
• Communications: development and execution of communications through the available data and means of contact (e-mail, instant messaging, etc.) with categories of internal stakeholders (employees) and external stakeholders (customers, prospects, collaborators, suppliers, etc.). The purposes of such communications may be informative, organizational, commercial and advertising, as appropriate on the basis of informed consent, legitimate interest of the responsible or other existing legitimate basis.
• Other purposes derived from the nature of the data controller, motivated in the normal development and exercise of its activity, from a valid legitimate basis.

• How long will we keep your data?

In general, personal data will be kept at least as long as there is a relationship with the person concerned, as long as their deletion is not requested, as long as liabilities may arise or as long as there is a legal provision for their retention.

With regard to the data of candidates and job seekers, they will be deleted immediately when they are no longer of interest to the person in charge.

The data controller has in its data protection plan an inventory of retention periods that it observes to manage the different applicable retention periods.

The deletion of the data will be carried out in any case ensuring their confidentiality.

• What is the legitimacy for the processing of your data?

The controller observes and applies the various existing legitimate bases that apply to each purpose of processing. These are:

1. Informed consent of the interested party.
2. Pre-contractual or contractual commitments.
3. Legitimate interest of the responsible party.
4. Applicable legal obligations.
5. Other legally prescribed legal grounds.

• To which recipients will your data be communicated?

The data of the interested parties will not be communicated to any third party by default, except: a) auxiliary services, authorized data processors or other implicit third parties necessary for the correct provision of goods and services; b) authorities and public administrations competent in the exercise of their functions; c) other legitimate interested parties and legally foreseen third parties.

• What are your rights when you provide us with and/or we process your data?

As a data subject, you may at any time request us to exercise any of the following data protection rights:

• Access to the data subject's personal data to confirm whether or not data concerning him/her are being processed and to obtain more information about this processing.
• Rectification or deletion of personal data concerning the data subject when, among other reasons, they are inaccurate or no longer necessary for the purposes for which they were collected.
• To limit the processing of the data subject's personal data in certain circumstances, in which case it will only be retained for the purpose of the exercise or defense of claims, for the protection of the rights of another person or for reasons of public interest.
• Receive the personal data concerning you, which you have previously provided to us, and in a structured format where possible (portability of your data).
• Oppose the processing of your data in certain circumstances and for reasons related to your particular situation. The company will stop processing your data, except for compelling legitimate reasons, or the exercise or defense of possible claims.
• To revoke consent, which may entail the annulment or cancellation of the existing business or contractual relationship, if any. Without prejudice to the processing carried out prior to the withdrawal of consent.

To do so, you only need to contact us through the email or postal address indicated at the beginning of this page.

Alternatively, you can also contact our data protection officer or to the Data Protection Agency to learn more about your rights or to request the protection of your rights by the supervisory authority.

• Data security.

We adopt in our information system the necessary technical and organizational measures to ensure an adequate level of confidentiality, integrity, availability and resilience of data in order to protect the rights and freedoms of data subjects.

The data controller complies with the provisions and principles described in the GDPR to process the data in a lawful, fair and transparent manner in relation to the data subject, and adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

However, to the extent permitted by law, we do not assume any responsibility for damages or alterations that third parties may cause in our information system. Any breach of security will be immediately and conveniently reported to the competent authority and/or law enforcement agencies.

• Sending communications or information.

Our policy with respect to sending information through telematic means (e-mail, instant messaging, etc.), is limited to sending only communications that we consider of interest to our users and interested parties, in relation to the functions and activity of the company, or that you have consented to receive.

If you prefer not to receive these messages, we will offer you through these the possibility of exercising your right to cancel and waive the receipt of these messages, in accordance with the provisions of Title III, Article 22 of Law 34/2002 of Services for the Information Society and Electronic Commerce.

• Social networks.

The responsible may have a presence in social networks through the corresponding profiles, being applicable this section and any legal and privacy terms present on the website for the processing of data of users or interested parties who become followers or in any way linked to such profiles.

The purposes of use of these profiles by the responsible are communication, business development, marketing and advertising, processing queries posed to the responsible and user service, reporting on actions, activities and events organized by the responsible or in which it participates, and interacting through the official profiles.

The legitimate bases set out in section 6 above are complemented in this case because the user or data subject may have a profile on the same social network as the data controller and has decided to join or connect with the data controller's profile, thus showing interest in the information published by the data controller. Therefore, at the time of following the profiles of the data controller, he/she provides his/her consent to the processing of those data available on his/her profile.

The user can access at all times to the privacy policies and terms of the corresponding social network, as well as configure the privacy features that can be carried out in your profile. The publications made by the user will be known by other users, so the user is primarily responsible for their privacy.

Users who are followers and/or participants in our profiles will abstain:

1. To publish content or information contrary to the law, morality and good faith. It is not allowed any use or behavior that is illicit, annoying, inappropriate, that may generate negative opinions in the profile or that violates the rights of persons.
2. To behave in a manner contrary to the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of privacy, consumer protection and intellectual and industrial property rights.

The responsible reserves the right to remove without prior notice any content deemed inappropriate. It also disclaims any liability in connection with the security measures for each platform, and the user must be aware of them along with the legal terms and conditions of use of the platform itself.

The responsible party shall be expressly exonerated from any liability that may arise from the use of social networks by minors or persons with special abilities. The social networks of the responsible party do not knowingly collect any personal information from minors, therefore, if the user is a minor, he/she must not register, use the social networks of the responsible party, or provide any personal information. Particularly in Spain, the processing of personal data of a minor may only be founded from the age of 14 years. On the other hand, if any rule or regulation so requires, or the user has special abilities, the intervention of the holder of parental authority or guardianship, or his legal representative by means of a valid document proving the representation will be necessary.

• Employment and applicant management

Those interested in accessing job offers from the responsible party may provide their data and professional information to the responsible party through different channels, preferably through contact forms, e-mail addresses, and existing means for this purpose, where appropriate.

These data will be processed in accordance with these terms of privacy herewith for the purpose of managing applications for possible job offers, internships and training of the responsible entity and any affiliated companies or companies belonging to the same business organization, where it exists and where appropriate.

The processing will be carried out on the basis of the data subject's informed consent or other valid legitimate basis.

The data provided, if they are not of professional interest to the entity or once they are no longer necessary for the purposes for which they were collected, will be deleted ensuring their confidentiality and anonymization.

Any data subject may revoke his or her consent and exercise his or her privacy rights under the terms set forth in this privacy policy.