Privacy Policy

1.- What is the purpose of this policy?

 The purpose of this Privacy Policy (hereinafter also policy) is to inform the interested parties whose data is processed through the CRM tool used by BOLUDA LINES, S.A., detailed information about the processing of their personal data.

For this Privacy Policy, the individuals whose categories are described in this policy and who are the owners of the personal data processed in the CRM tool used by BOLUDA LINES, S.A. will be considered interested parties.

2.- What regulations apply to this policy?

The processing of the data of the persons concerned carried out by BOLUDA LINES, S.A. is under the scope of application of the legislation in force in Spain on data protection and, in particular, of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals concerning the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter GDPR); of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights (LOPDGDD); and of Law 34/2002, of 11 July, on information society services and electronic commerce.

3.- Who is the data controller?

BOLUDA LINES, S.A. (hereinafter BOLUDA LINES) is the company responsible for the processing of the data of the persons concerned. The contact details of BOLUDA LINES are as follows :

Postal address: Calle del Capitán Haya, 21, 28020 Madrid, Spain.

E-mail address: rgpd@boluda.com.es.

Telephone: 914183675.

4.- What categories of data subjects are processed?

The persons concerned whose data are processed by BOLUDA LINES relate to the following categories:

Clients of this company are constituted as natural persons, self-employed professionals, and/or individual entrepreneurs.

Physical contact persons and regular interlocutors who are part of the structure or staff of the client legal entities with whom BOLUDA LINES maintains legal relations.

Physical contact persons who are part of the structure or staff of other legal entities that are not clients of BOLUDA LINES and maintain commercial relations with BOLUDA LINES and potential clients constituted as self-employed professionals and/or individual entrepreneurs of BOLUDA LINES.

5.- What types of data are processed?

The data processed by BOLUDA LINES concern identification data, personal characteristics, and economic data concerning the persons concerned.

6.- Where does the data come from?

The data of the persons concerned processed by BOLUDA LINES have been provided from various sources indicated below:

BOLUDA LINES customer data has been obtained by BOLUDA LINES from the customers themselves who have provided it to BOLUDA LINES for the development and maintenance of the contractual relationship.

The data of the usual contact persons and interlocutors within the legal entity clients of BOLUDA LINES have been obtained by BOLUDA LINES either from the contact persons and interlocutors themselves or from third parties other than these contact persons and interlocutors.

Finally, the data of contact individuals who are part of the structure or staff of third party legal entities, not clients of BOLUDA LINES with whom BOLUDA LINES maintains commercial relations and of potential clients constituted as self-employed professionals and/or individual entrepreneurs of BOLUDA LINES, have been obtained by BOLUDA LINES through different entry channels such as, but not limited to, email, telephone, website www.boluda.com, other websites, BOLUDA LINES transactional systems, door to door and events.

7.- On what legal basis and for what purposes are the data processed?

The data of the persons concerned are processed by BOLUDA LINES on the legal basis and for processing indicated below:

a) Interested persons who are customers of BOLUDA LINES:
  • With a legal basis in compliance with legal obligations and the execution of the contractual relationship, BOLUDA LINES customer data will be processed for the development of the contractual relationship, including customer registration, administrative, accounting, fiscal and billing management, collections and payments, communications management and the sending of any type of communication-related to the execution of the contract.
  • Likewise, if the clients have given their consent to BOLUDA LINES, by ticking the box presented for this purpose by this company, with legal basis in the consent, the data of said clients will be processed to send them commercial communications by e-mail, related to the maritime transport and international cargo management services provided by BOLUDA LINES as well as invitations to events organized, sponsored or in which BOLUDA LINES is a party.
  • If clients do not authorize the sending of commercial communications and/or request BOLUDA LINES to revoke the consent given or oppose the receipt of said commercial communications, with legal basis in compliance with legal obligations, the data of said clients will be processed to avoid and not carry out the sending of said commercial communications.
b) Interested persons who act as contact persons and interlocutors within BOLUDA LINES’s legal entity clients:
  • With a legal basis in the legitimate interest determined by Law, the data of the natural persons of contact and interlocutors within the natural person’s clients of BOLUDA LINES will be treated to maintain the contractual relationship and legal relations of any nature with the legal person in which the natural person of contact and interlocutor provides its services, which includes treating the data for administrative, accounting, fiscal and billing management, collections and payments, the management of communications and the sending of any type of communication-related to the execution of the contract.
  • Likewise, if the contact persons and interlocutors within BOLUDA LINES’s clients have given their consent to BOLUDA LINES, by ticking the box provided for this purpose by this company, with legal basis in the consent, the data of said contact individuals and interlocutors will be processed to send them commercial communications by e-mail, related to the maritime transport and international cargo management services provided by BOLUDA LINES as well as invitations to events organized, sponsored or in which BOLUDA LINES is a party.
  • If the contact persons and interlocutors within BOLUDA LINES’s clients do not authorize the sending of commercial communications and/or request BOLUDA LINES to revoke the consent given or oppose the receipt of said commercial communications, with legal basis in compliance with legal obligations, their data will be processed to prevent and not carry out the sending of the aforementioned commercial communications.
c) Interested persons acting as physical contact persons within legal entities that are not BOLUDA LINES clients and potential BOLUDA LINES clients constituted as self-employed professionals and/or individual entrepreneurs:
  • If these contact individuals or potential customers of BOLUDA LINES have given their consent to this company, by ticking the box provided for this purpose by BOLUDA LINES, with legal basis in the consent, the data of such contact individuals and potential customers of BOLUDA LINES will be processed to send them commercial communications by email, related to shipping services and international cargo management provided by BOLUDA LINES as well as invitations to events organized, sponsored or in which BOLUDA LINES is a party.
  • If the contact individuals or potential clients of BOLUDA LINES do not authorize the sending of commercial communications and/or request BOLUDA LINES to revoke the consent granted or oppose the receipt of said commercial communications, with legal basis in compliance with legal obligations, their data will be processed to prevent and not carry out the sending of the aforementioned commercial communications.

 8.- Is the data communicated to third parties?

The data of the persons concerned are communicated by BOLUDA LINES to third parties, based on the following legitimate conditions and for the purposes indicated below:

a) Interested persons (self-employed professionals and/or individual entrepreneurs) who are clients of BOLUDA LINES:
  • With a legal basis in compliance with legal obligations and the execution of the contractual relationship, the data of BOLUDA LINES clients will be communicated to the following third parties: (i) financial institutions for the payment of the contracted services or goods; (ii) Tax Agency for the fulfillment of tax obligations; (iii) auditors for the performance of financial audits; and (iv) Public Administrations competent because of the subject matter.
b) Interested persons who act as contact persons and interlocutors within BOLUDA LINES’s legal entity clients:
  • On the legal basis of the fulfillment of legal obligations and the execution of the contractual relationship, the data of the natural persons of contact and interlocutors within the legal entity clients of BOLUDA LINES may be communicated to the following third parties: (i) auditors for the performance of financial audits; and (ii) Public Administrations competent because of the subject matter.
c) The data of interested persons acting as contact persons within legal entities that are not customers of BOLUDA LINES and potential customers of this company will not be disclosed to third parties unless legally required.

In any case, the data of the data subjects processed by BOLUDA LINES will be made available to third party processors contracted through the subscription of processing orders for the provision of services related to the hosting of data, tax management, auditing, the provision of IT services and other auxiliary and support services to the activity of BOLUDA LINES. The data processors are obliged to process the data according to the instructions given by BOLUDA LINES through a data processing contract with sufficient guarantees of security and confidentiality.

9.- Are data transfers carried out?

The data of the persons concerned will not be transferred by BOLUDA LINES to third countries or international organizations.

10.- How long will the data be kept?

The data of the persons concerned will be kept by BOLUDA LINES for as long as the purposes and legal bases of the processing are maintained and for the legal periods for the fulfillment of obligations and attention of possible responsibilities.

11.- What rights do the persons concerned have?

At any time, the persons concerned have the possibility of exercising their rights of access, rectification, deletion, opposition, limitation of processing, portability, as well as the right not to be subject to decisions based solely on the automated processing of their data.

You also have the right to withdraw your consent to the processing of your data concerning the processing purposes described in this Privacy Policy on the legal basis of consent (without affecting the lawfulness of the processing based on consent before its withdrawal).

Data subjects also have the right to object to the processing of data concerning them on grounds relating to their particular situation, in connection with the data processing described in this policy based on legitimate interest.

The exercise of any of these rights may be exercised by the interested party by sending a request, indicating the right being exercised, to any of the following addresses:

Postal: Calle del Capitán Haya, 21, 28020 Madrid, Spain.

Electronics: rgpd@boluda.com.es.

Given that these are very personal rights, BOLUDA LINES may ask the interested parties to provide a photocopy of both sides of their DNI/NIF or any other legal document that identifies them, when necessary to prove their identity.

Likewise, interested parties may revoke the consent given or oppose the reception of commercial communications about the integral maritime transport and international cargo management services provided by BOLUDA LINES as well as invitations to event