To receive and process your communication, you must confirm that you have read this Privacy Notice. If you do not accept the terms and conditions as set out in the Privacy Notice, you will not be able to make the communication.
The whistleblowing channel is managed by the Armas Trasmediterránea Group (hereinafter, the Group), using the ithikios platform, owned by Digital Products Development SL, which maintains a contractual relationship with the Group in its capacity as Data Processor for the purpose of receiving, storing, and sending communications to the Group's Compliance team.
Ithikios guarantees security and confidentiality for the purpose of the contracted processing.
Likewise, Grupo Armas-Trasmediterránea guarantees the confidentiality of the complainant, the reported party and any other person who may be related, as well as the content of the complaint. There will be no adverse consequences of any kind because of making a report, provided that the report has been made in good faith.
Below you will find information on how we process your personal data:
Personal Data Protection Information
| Data Controller | Company of the Armas Trasmediterránea Group affected by the reported facts. |
| Main Purpose | Receipt and management of complaints received through the whistleblowing channel, as well as the investigation of files relating to infringements to detect offences and prevent criminal liability of the companies of the Armas Trasmediterránea Group and to prevent conduct contrary to the Group's internal regulations, as well as any other that may be applicable. |
| Lawfulness of processing | - The processing is based on the public interest in accordance with the provisions of Article 6.1.e) GDPR in relation to the Preamble section V of the LOPDgdd. - The Processing is necessary for compliance with a legal obligation applicable to the controller. |
| Data Category | - Name and surname, phone, and e-mail (if the complaint is not anonymous). - Facts related to the allegations and other information provided by the complainant such as name and surname of the complainant and witnesses, personal characteristics, employment details, signature... - Administrative offences and penalties. - No data of special categories will be processed, except those that may be provided by the complainant. |
| Recipients | Data from the whistleblowing channel will be communicated to external professional cloud hosting service providers and whistleblowing channel management providers who will process the data as Data Processors and, where necessary, to the head of the HR department for the adoption of sanctions or disciplinary measures.
The facts that may constitute a criminal or administrative offence, including personal data, may be communicated to the Security Forces and Corps, the Public Prosecutor's Office, the Judiciary, or other public administrations with competence in relation to the type of communication submitted.
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| Transfers of personal data | No international transfers will be made in connection with this processing, except to competent authorities outside the national territory based on public interest or the fulfilment of legal obligations for the formulation, exercise, or defence of claims |
| Profiling | The entity will not create profiles or automated individual decisions based on this processing. |
| Rights | The data subject may exercise his/her rights of access, rectification, deletion and portability of his/her data, limitation and opposition to the processing thereof, as well as the right not to be subject to decisions based solely on the automated processing of his/her data, where applicable, before the Company of the Armas Trasmediterránea Group affected by the facts communicated through the following address [email protected]. Data subjects also have the right to lodge a complaint with the Supervisory Authority (Spanish Data Protection Agency): www.aepd.es). |
| The period for which the personal data will be stored | The personal data will store in accordance with the provisions of the applicable legislation. The data will keep only for the time necessary to decide whether to initiate an investigation into the reported facts, which may be extent for a maximum of three (3) months from the registration of the Communication/Complaint. In any case, after that time, all such data shall be deleted from the system, unless the purpose of storage is to leave evidence of the operation of the channel, in which case they shall be anonymized. However, if it is necessary to process personal data for a longer period to continue the investigation or because it is decided to take legal action, the data will be kept, in an environment other than the whistleblowing channel, for as long as it is necessary to conclude the investigation or for the exercise of actions by the Group in the corresponding legal proceedings. In any case, after that time, all such data shall be deleted from the system, unless the purpose of the retention is to leave evidence of the functioning of the channel, in which case they shall be anonymised. However, should it be necessary to process the personal data for a longer period of time in order to continue the investigation or because it is decided to take legal action, the data shall be kept, in an environment other than the Ethical Channel, for as long as it is necessary to conclude the investigation or for the exercise of actions by Grupo Armas Trasmediterránea in the corresponding legal proceedings. Communications/complaints that have not been followed up will only be recorded in the system in an anonymised form, but will not be blocked |
Last update: 10 December 2021.