In order to ensure compliance with its Code of Conduct, GHESA is offering its interest groups an Ethics Box to allow
them to report and provide information and documentation on any possible irregularity or illegal behaviour by way of the internet,
so that the Compliance Committee can initiate an investigation. The report may include any documentation that is deemed appropriate.
GHESA guarantees that the IT tools used in the process will maintain the confidentiality and preserve the identity of the reporting party, which will not be transmitted to the reported party without the former’s approval. This will guarantee that the identity of the reporting party remains unknown and thus avoid any kind of possible retaliation from the reported party.
In any event, communications shall always observe principles of truthfulness and proportionality. This system cannot be used for any purposes other than those implemented to ensure compliance with the GHESA Code of Conduct.
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1. Company information: GHESA
In compliance with article 10 of Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce, the company's identification details follow:
Company Name: GHESA S.A.
Nif / Cif: A28126274
Registered Address: CALLE MAGALLANES 3
2. Intellectual Property Rights
The source code, graphic design, images, photographs, sounds, animations, software, texts, as well as the information and contents included in www.GHESA.com are protected by Spanish legislation on intellectual and industrial property rights in favour of GHESA S.A. (hereinafter GHESA) and the reproduction and/or publication, in whole or in part, of the website, its processing by computer, distribution, dissemination, modification, transformation or decompilation, or other rights legally recognised to its owner, without prior written consent from GHESA, is not permitted. The user may use the material that appears on this website solely and exclusively for personal and private use, its use for commercial purposes or to engage in illegal activities being prohibited. All intellectual property rights are expressly reserved by GHESA. GHESA will watch over the compliance of the above conditions, as well as the correct use of the contents presented in its website, taking pertinent civil or criminal action in case of infringement of or non-compliance with these rights by the user.
3. Protection of personal data
B.- GHESA can modify, without prior notice, the information contained on its website, as well as its settings and presentation.
C.- GHESA hereby undertakes NOT TO ENGAGE IN MISLEADING ADVERTISING. To these effects, misleading advertising does not include formal or numerical errors which may be found in the different sections of GHESA's website, caused by incomplete or faulty maintenance or updating of the information contained in these sections. GHESA, in accordance with this paragraph, undertakes to correct these errors as soon as it becomes aware of them.
D.- GHESA undertakes NOT TO SEND ADVERTISING CORRESPONDENCE WITHOUT IDENTIFYING IT AS SUCH, in accordance with Law 34/2002 on Information Society and Electronic Commerce Services. Thus, no information sent TO THE CLIENTS of GHESA will be considered as advertising correspondence, provided its object is to maintain the existing contractual relationship between client and GHESA, as well as to carry out the tasks of information, training and other activities related to the service which the client has contracted from the company.
E.- GHESA is not responsible for the user’s failure to comply with any applicable rule or regulation in his or her access to the website www.GHESA.com and/or in the use of the information contained therein.
F.- GHESA will not be responsible for any damages, whatever their nature, derived from the use of the information, the contents of this website and the programmes included in it. The links and hypertext which, through the website www.GHESA.com, allow the user to access features and services offered by third parties do not belong to and are not under the control of GHESA; the company is not responsible for the information contained therein or for any effects which may derive from this information.
G.- GHESA is not responsible for the illegitimate use that third parties may make of the brand names, product names and trademarks which, not being the property of said entity, appear on the Website www.GHESA.com. Likewise, it is not responsible for the integrity, veracity and legality of the content of the web links that can be accessed from www.GHESA.com.
H.- GHESA is not responsible for the viruses that originate in a telematic transmission infiltrated by third parties (for example, macros of word processors, Java applets and Active X programs), generated in order to obtain negative results for a computer system.
I.- In short, the User alone is responsible for the use he/she makes of the services, contents, links and hypertext included on the website www.GHESA.com.
J- GHESA does not guarantee the availability and continuity of the operation of the Website and shall in no case be liable for any damages that may result from (i) the lack of availability or accessibility to the Website or to those other sites with which a link has been established; (ii) the interruption in the functioning of the Website or computer failures, disconnections, delays or blockages whatever the cause, in the Internet system or in other electronic systems produced in the course of its operation; (iii) the lack of suitability of the Website for the specific needs of Users and (iv) other damages that may be caused by third parties through unauthorized interference beyond the control of GHESA.
GHESA wishes to inform the users of this website that this declaration reflects the data protection policy followed by GHESA. This policy has been designed in strict compliance with the current legislation on the protection of personal data, including, among other legal provisions, Regulation (EU) 2016/679 of 27 April 2016 (hereinafter, RGPD).
GHESA does not voluntarily collect personal data from the users of this Website. The only data that is requested from Users is that which the User voluntarily provides through the different forms on the website. Consequently, GHESA will only have personal data of those users who voluntarily wish to provide such data to the company. Only in these cases in which the User so wishes, and always on a voluntary basis, may he/she communicate his/her personal data to GHESA.
These data voluntarily provided by the user may be incorporated into an automated file under the ownership of GHESA. In any case, the data collected will be treated at all times in accordance with current legislation on the protection of personal data.
This policy may be modified or updated from time to time to reflect changes in GHESA's practices with respect to the processing of personal data or changes in applicable law. We encourage users to read this policy carefully and to check the website regularly to see if changes have occurred in accordance with the terms of this policy.
Collection of personal data
1. Person Responsible
GHESA, Ingeniería y Tecnología, S.A., a company domiciled in Madrid (Spain), incorporated in Madrid before the notary Mr. Ramón Corral Beneyto, registered in the Mercantile Register of MADRID in volume 293, folio 122, with Tax Identification No. A28126274 (hereinafter GHESA) is the owner of the website located in the Domain www.ghesa.com. In order to guarantee the proper processing of personal data, GHESA has appointed a Data Protection Officer, who can be contacted with any queries regarding the processing of your personal data via the address LMT@ghesa.es .
- Contact: to manage the data of the users who contact GHESA, either through the contact forms on the website, by telephone call, e-mail or any other means.
Additionally, the data may be processed for the purpose of maintaining contact with users, providing services related to customers and managing any requests that may be made through the GHESA web pages.
GHESA can also process, for the same reasons as those set out in the previous paragraph, the personal data of users who have contacted the company by means other than through its web pages.
- Commercial communications: Commercial communications of GHESA's products and services: GHESA may process users' personal data for the purpose of sending them commercial communications of the products and services it offers and that it considers may be of interest to the user. GHESA informs that the aforementioned commercial communications may be received by postal mail, telephone calls or electronic means (e-mail, text messages or other electronic means of communication).
The user may at any time object to the processing of his/her personal data for the purpose of receiving commercial communications, through any channel made available to him/her, as explained below in the section entitled 'Exercise of rights'.
3. Personal data processed and information obtained
GHESA collects personal data from the following sources:
- Personal data voluntarily provided by the users (for example, when you contact the company via e-mail or telephone or any other means such as entering personal information in the forms on GHESA's web pages).
- Personal data obtained in the ordinary or contractual course of the company's relationship with the interested parties.
GHESA may process the following categories of personal data, subject to the applicable legal regulations:
- Personal and contact details such as name, address, telephone number and e-mail address of potential candidates for jobs at GHESA. In other contact forms, it is recommended to include as contact information, whenever applicable, the contact details of the company in which the user provides his or her services. In the event that the user decides to send his/her CV through GHESA's website with the aim of occupying a position in the company, his/her information will be treated exclusively for this purpose and will be kept for the period necessary to comply with the applicable legal and administrative obligations.
The legitimation to process the data is based on the consent obtained from the user. In addition, GHESA treats the personal data of the users who voluntarily provide it in accordance with the following legitimating bases:
- The processing of personal data for the purposes of 'Contact' is based, in addition to consent, on the management of the legal relationship established between the user and GHESA. This basically includes managing the request, maintaining contact between both parties and, if applicable, satisfying the service required by the user.
- The processing of personal data communicated in the form section 'Work with us' is based on the user's consent.
- The processing of personal data communicated in the Ethical Channel form is based on the user's consent.
5. Disclosure of personal data to third parties
The personal data collected through this Website will not be transferred to any other subject or company, except to the subjects and in the specific cases in which such transfer is covered by the General Data Protection Regulations. The User who voluntarily communicates his/her data to GHESA through this Website expressly consents to the use of said personal data for the sending by electronic means of commercial information on the products and services marketed by GHESA, in strict compliance with the provisions of the current legislation on Information Society Services, as far as commercial communications are concerned, unless he/she expresses his/her opposition. Likewise, the User who voluntarily communicates his/her data to GHESA through this Website expressly consents to the use of said personal data for the sending of commercial information, including by electronic means, from the companies linked to GHESA, whose company name and activity are included on the website http://www.ghesa.com/avisolegal.html in strict compliance with the provisions of current legislation on the protection of personal data and Information Society Services, unless he/she expresses his/her opposition.
6. Security measures
The personal data communicated by the User to GHESA may be stored in databases, computerized or not, whose ownership corresponds exclusively to GHESA, which undertakes all the technical, organisational and security measures at its disposal to guarantee the confidentiality, integrity and quality of the information contained therein in accordance with the provisions of the RGPD. In any case, it should be borne in mind that Internet security measures are not impregnable and the user is responsible for ensuring that all personal information that may be provided to GHESA is sent securely.
7. Duties of the user who provides personal data
The user guarantees that the personal data provided is true, accurate, complete and up to date. The user is liable for any damage, direct or indirect, caused by failure to comply with this obligation. In the event that the user provides personal data of third parties, the user guarantees to have informed such third parties of the content of this policy and to have obtained prior consent to provide their data for the purpose of processing in question. You must be over 16 years old to provide your personal data. The users who provide personal data through GHESA's websites declare and guarantee that they are over 16 years of age and are fully responsible for their declaration.
8. Retention of data
Personal data will be kept for the duration of the relationship established with GHESA as well as for the required legal periods.
9. Exercise of rights
GHESA informs you that you have the right to obtain confirmation as to whether or not we are processing personal data concerning you.
Likewise, GHESA informs you that you have the following rights regarding your personal data:
- Access to your data: you have the right to access your data in order to know what personal data we are processing concerning you.
- To request the rectification or deletion of your data: in certain circumstances, you have the right to rectify any personal data that you consider to be inaccurate and that concerns you and that is processed by GHESA, as well as the right to request the deletion of your data when, among other reasons, the data are no longer necessary for the purposes for which they were collected.
- To request a restriction on the processing of your data: in certain circumstances, you are entitled to request a restriction on the processing of your data, in which case we inform you that we will only retain the data on which you have requested a restriction on their processing for the purpose of exercising or defending claims.
- To the portability of your data: in certain circumstances, you will have the right to receive the personal data that concerns you, and that you have provided to us, in a structured common use and machine readable format, as well as to have them transmitted by GHESA to another responsible data processor.
- To oppose the processing of your data: in certain circumstances and for reasons related to your particular situation, you have the right to object to the processing of your data. In these cases, we will cease to process your data unless we must continue to do so for compelling legitimate reasons or for the exercise or defence of any claims.
We also remind you that you have the right to object, at any time, to the sending of advertising for GHESA's own products and services.
Finally, we would inform you that you may file a complaint with the competent Data Protection Authority. However, you may first lodge a complaint with the Data Protection Officer of GHESA (LMT@GHESA.ES), who will resolve the complaint within a maximum period of two months.
A cookie is a file that is placed on your device when you visit a website. This file collects information about your device, your browser and your browsing preferences and habits. GHESA treats them in accordance with its Cookies Policy, shown in http://www.GHESA.com/avisolegal.html.
GHESA's web pages provide, in some cases, links to other digital platforms or contents that are owned by third parties. The sole purpose of the links is to provide the user with the possibility to obtain supplementary information through these links. GHESA accepts no responsibility whatsoever for the results that may derive from the user's accessing these links.
12. Contact details
Magallanes Street, 3-9ª • 28015 MADRID • Phone: 91 309 81 00 • Fax: 91 594 24 28 • www.ghesa.es