Privacy Policy

1.- What is the purpose of this policy?

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

For the purposes of 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 TOWAGE, S.L. 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 TOWAGE, S.L. is under the scope of application of the legislation in force in Spain regarding 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 natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter RGPD); 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.- Which entity is the data controller and which entities are co-responsible for the data processing?

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

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

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

Telephone: 914183675

Likewise, each of the subsidiary companies of BOLUDA TOWAGE located in Europe and in third countries (hereinafter also referred to as Corresponsible Entities), whose identities and contact details can be consulted, at any time, in the updated list published in this link Boluda-Towage_Companies of the website  (through this link you can directly access the companies), are jointly responsible for the processing of the data of the persons concerned, under an agreement of joint responsibility and international transfer of data signed between BOLUDA TOWAGE and its subsidiaries listed in the aforementioned link.

Interested persons can request and obtain information on the essential aspects of the co-responsibility agreement by sending an email to: rgdp@boluda.com.es.

4.- What categories of data subjects are processed?

The interested parties whose data are processed by BOLUDA TOWAGE and the Corresponsible Entities are in the following categories:

  • Customers of BOLUDA TOWAGE are constituted as individuals, self-employed professionals and / or sole proprietors.
  • Physical contact persons and regular interlocutors who are part of the structure or staff of the client legal entities with whom BOLUDA TOWAGE maintains legal relations.
  • Physical contact persons who are part of the structure or staff of other legal persons who are not BOLUDA TOWAGE clients and who maintain commercial relations with BOLUDA TOWAGE as well as potential clients constituted as self-employed professionals and/or individual entrepreneurs of BOLUDA TOWAGE.

5.- What types of data are processed?

The data processed both by BOLUDA TOWAGE and by the Correspondent Entities refer to identification and location data, social circumstances data, economic data and data on transactions of goods and services concerning the persons concerned.

6.- Where does the data come from?

The data of the persons concerned have been provided from the various sources listed below:

  • The data of BOLUDA TOWAGE’s clients (constituted as natural persons, self-employed professionals and/or individual entrepreneurs) have been obtained by BOLUDA TOWAGE from the interested persons themselves, who have provided them to BOLUDA TOWAGE for the development and maintenance of the contractual relationship.
  • The data of the contact persons and usual interlocutors within the legal entity clients of BOLUDA TOWAGE have been obtained either from the contact persons and interlocutors themselves or from the legal entity in which they provide their services.
  • Finally, the data of natural contact persons who are not BOLUDA TOWAGE customers and are not part of either of the two previous groups, have been obtained by BOLUDA TOWAGE through different input channels such as, but not limited to, email, telephone, websites or web pages and events organized by BOLUDA TOWAGE.

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

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

a) Interested persons who are customers of BOLUDA TOWAGE:
  • With a legal basis in compliance with legal obligations and in the execution of the contractual relationship, BOLUDA TOWAGE 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.
  • Furthermore, in the event that customers have given their consent to BOLUDA TOWAGE through the various means made available to them by BOLUDA TOWAGE (such as ticking boxes for specific purposes), based on the legal basis of the consent, the data of such customers will be processed in order to send them commercial communications by e-mail related to port, coastal, offshore and maritime rescue towage services, as well as invitations to events organized, sponsored or in which BOLUDA TOWAGE is a party.
  • In the event that clients do not authorize the sending of commercial communications and/or request BOLUDA TOWAGE 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 in order to avoid and not carry out the sending of said commercial communications.
b) Interested persons who act as contact persons and interlocutors within BOLUDA TOWAGE’s legal entity clients:
  • With legal basis in the legitimate interest determined by Law, the data of the natural persons of contact and interlocutors within the natural persons clients of BOLUDA TOWAGE, 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 the management of the registration of that legal person, 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.
  • Furthermore, in the event that the contact persons and interlocutors within BOLUDA TOWAGE’s customers have given their consent to BOLUDA TOWAGE through the various means made available to them by BOLUDA TOWAGE (e.g. by ticking boxes for specific purposes), based on the legal basis of the consent, the data of these contact persons and interlocutors will be processed in order to send them commercial communications by e-mail, related to port, coastal, offshore and maritime rescue towage services, as well as invitations to events organized, sponsored or in which BOLUDA TOWAGE is a party.
  • In the event that the contact persons and interlocutors within BOLUDA TOWAGE’s clients do not authorize the sending of commercial communications and/or request BOLUDA TOWAGE 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 TOWAGE clients and potential BOLUDA TOWAGE clients constituted as self-employed professionals and/or individual entrepreneurs:
  • In the event that these contact persons or potential BOLUDA TOWAGE customers have given their consent to BOLUDA TOWAGE through the various means made available to them by BOLUDA TOWAGE (such as ticking boxes for specific purposes), on the legal basis of the consent, the data of such contact persons and potential customers of BOLUDA TOWAGE will be processed in order to send them commercial communications by e-mail, related to port, coastal, offshore and marine salvage towage services, as well as invitations to events that BOLUDA TOWAGE organizes, sponsors or is a party to.
  • In the event that the interested parties indicated in the previous section do not authorize the sending of commercial communications and/or request BOLUDA TOWAGE to revoke the consent given or oppose the receipt of said commercial communications, with a 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.

 Likewise, the data of the persons concerned are processed by BOLUDA TOWAGE and by each of the Corresponsible Entities on the legal bases and for the purposes of processing indicated below:

  • Based on the legitimate interest of both BOLUDA TOWAGE and each of the Corresponding Entities to maintain a global vision of their business that allows them to execute opportunities to improve their processes at a group level for clients, as well as for the purpose of managing the processes and business functions centralized and distributed among the aforementioned companies in a corporate manner, the data of the interested parties who are clients and/or who are physical contact persons and/or interlocutors within the structure or work force of said clients, are processed in order to identify the persons concerned, either as clients or as physical contact persons and/or interlocutors within the clients, to identify the services and business relationships provided by BOLUDA TOWAGE and the Correspondent Entities and the interactions maintained with the persons concerned and to analyse how to improve the efficiency, competitiveness and organisation of the services provided by BOLUDA TOWAGE and the Correspondent Entities.
  • Likewise, in the event that the interested parties have given their consent to BOLUDA TOWAGE through the various means made available to them by BOLUDA TOWAGE (such as ticking boxes for specific purposes), on the legal basis of the consent, the data of said interested parties will be processed by BOLUDA TOWAGE’s subsidiaries located in Europe and in third countries, for the purpose of sending commercial communications by e-mail about the towing, mooring, maritime transport, maritime terminal services, also described at https://www.boluda.com.es/en/boluda-towage-salvage-en/, that they provide and events that they organize, sponsor or in which they are part of, according to the segmentation criteria that, at each moment, determines the company that sends the commercial communication, not taking decisions based solely on automated processing, including profiling.
  • In the event that the interested parties do not authorize the sending of such commercial communications by the Corresponsible Entities and/or request the revocation of the consent granted or opposition to the receipt of such commercial communications, respecting this decision and with legal basis in compliance with legal obligations, the data of the interested parties will be processed solely for the purpose of avoiding and not carrying out any further sending of the aforementioned commercial communications. However, this will not prevent both BOLUDA TOWAGE and the Corresponsible Entities from maintaining the joint and shared processing of t