This Privacy Policy (hereinafter the “PRIVACY POLICY”) regulates, in general terms, the collection and processing by INGETEAM, S.A. (hereinafter “INGETEAM”) of the personal data that you provide us with as a user of the website that is accessible through the domain name https://www.ingeteam.com/ (hereinafter the “WEBSITE”), including the blog services, social media, “Newsletter” information services or any other functionalities that may be available at any given moment through the WEBSITE. The foregoing is without prejudice to the specific provisions established in certain sections, forms or services available on the WEBSITE, for the purpose of providing you with the relevant information and, where appropriate, to obtain your consent.

INGETEAM reserves the right to amend the PRIVACY POLICY in order to comply with any new legislation, case law and/or administrative changes, and to comply with any practices developed at any time through the WEBSITE, taking account of your rights and interests at all times.

In any case, INGETEAM will provide you with appropriate technical resources so that you are able to access the PRIVACY POLICY, in order to duly comply with the information obligations which we need to observe, in compliance with the applicable data protection regulations.

1. Who is responsible for the processing of your data?

INGETEAM, S.A. (hereinafter, “INGETEAM”), a company with registered offices at Zamudio (Bizkaia), Parque Tecnológico de Bizkaia, Edificio 106, registered in the Companies Registry of Bizkaia in volume 5.764, folio 8, sheet BI-2.505.A and with Tax Identification Code (CIF) No. A-48420020.

For any questions related to the PRIVACY POLICY and/or the processing of your personal data, you can contact us at the postal address indicated above and/or through the following email address: gdpr.ingeteam@ingeteam.com

2. How do we collect your data?

The data processed at INGETEAM have been provided by you through (i) the different forms completed when browsing the WEBSITE (e.g. WEBSITE user registration, contact forms, forms referring to offers of employment and/or selection processes, etc.); or (ii) by sending an enquiry email.

If the personal data provided pertain to a third party, then you guarantee that you have informed the said third party of the PRIVACY POLICY and that you have obtained authorisation to provide his/her data to INGETEAM for the purposes indicated below.

Additionally, we would inform you of the possible processing of your social media data through the corporate profiles that INGETEAM maintains available on each social media platform in which it is present, all in the terms and conditions established for each social media site.

3. What type of data do we process?

The data processed at INGETEAM are those submitted by you through the appropriate forms that we use to formalise our contact with you and/or by email, in addition to the data which, where appropriate, we may obtain through the corporate profiles of INGETEAM in the social media in which we are present. 

Specifically, INGETEAM processes the following data categories, depending on your use of the WEBSITE:

• Identification and contact details (e.g. name, surnames, National Identity Document (DNI), postal address and email, phone, etc.).
• Identification codes and passwords as a registered WEBSITE user.
• Internet browsing details (e.g. IP address, website visits, WiFi network connections, etc.).
• Personal details, education, employment, etc. (with regard to job applications/vacancies and/or INGETEAM selection processes in which you are voluntarily taking part.

4. Why do we process your data and under what grounds of legitimate interest?

The processing of your personal data is for the following purposes:

• To manage and process your registration as a user, whenever possible, in addition to each of the services that you have requested.
• To process and manage any requests for information, suggestions, complaints or claims that you may make through the WEBSITE or email.
• To process and manage any contracting and provision of services that, where appropriate, you may enter into with INGETEAM through the WEBSITE.
• To send you, by different means, including electronic, business and advertising communications from INGETEAM and other companies forming part of the business group, and any other relevant information regarding the said entities, provided that you have given your consent to this.
• To manage your subscription to our “newsletter” service and to sending the corresponding electronic communications, provided that you have given your consent to this.
• To manage your job application or your registration for a job vacancy and your participation in the corresponding selection process.

The processing of your personal data by INGETEAM, in compliance with the applicable regulations, is based on your consent, granted at the time when you voluntarily provide us with your data through the mechanisms in place on the WEBSITE. 

We would remind you that you have the right to withdraw your consent freely and free of charge, at any time, in the terms indicated in Section 7 hereof.

5. Who do we disclose your data to?

We would inform you that your personal data may be disclosed to the following third parties:

• Public Administrations and Bodies to which, where applicable, INGETEAM is required by law to disclose your data.
• Entities of the business group of which INGETEAM is part, pursuant to Art. 42 of the Code of Commerce and for the purpose of dealing with your requests and enquiries and/or sending you commercial information regarding the said entities and their respective activities or products.

There are no plans for making international transfers of your Data.

6. How long will we store your data?

Generally, your personal data will be stored until you either withdraw your consent to the processing or request the erasure of the data. Your data will also be held for as long as is necessary to meet the legal obligations that INGETEAM must observe.

In any case, we would inform you that INGETEAM has established internal data cleansing policies directed at controlling the storage times for the personal data it holds. Therefore such data can be erased when no longer necessary and/or relevant to the purposes for which they were collected.

In particular, the following is stated:

• For the purpose of Managing and processing your user registration, your data shall be held for as long as the relationship continues or, otherwise, for a period of 5 years.
• For the purpose of Processing and managing requests for information, suggestions, complaints or claims through the Website, the data shall be held for as long as the relationship continues or, otherwise, for a period of 5 years.
• For the purpose of Processing and managing the contracting and provision of services through the Website, the data shall be held for as long as the relationship continues or, otherwise, for a period of 5 years.
• For the purpose of Sending you business communications, the data shall be held for as long as the relationship continues or, otherwise, for a period of 5 years.
• For the purpose of Managing subscriptions to our "Newsletter", the data shall be held for as long as the relationship continues or, otherwise, for a period of 5 years.
• For the purpose of Managing job applications, the data shall be held for a period of 2 years.

7. What are your rights?

The applicable data protection legislation grants you a series of rights relating to your personal data, which you may exercise during the processing of your data. These rights are indicated below:

• Access to your data: you have the right to access your data in order to find out what personal data concerning you are being processed by us.
• Request the rectification or erasure of your data: in certain circumstances, you have the right to rectify any inaccurate personal data concerning you and that are being processed by us, or even to request us to erase such data when, among other reasons, the data are no longer necessary in relation to the purpose for which they were collected.
• Request a restriction on the processing of your data: in certain circumstances, you have the right to ask us for a restriction on the processing of your data, in which case we can inform you that such data will only be kept for the exercise or defence of legal claims, as provided for in the applicable data protection regulations.
• To the portability of your data: in certain circumstances, you have the right to receive the personal data concerning you and that you have provided to us, in a structured, commonly used and machine-readable format and to transmit such data to another data controller .
• To object to the processing of your data: in certain circumstances and on grounds relating to your particular situation, you have the right to object to the processing of your data. In this case we would stop processing such data unless, due to compelling legitimate grounds, or the exercise or defence of possible legal claims, the data must be retained.

Likewise, you have the right to withdraw consent at any time, without this affecting the lawfulness of processing based on consent prior to withdrawal. 

You can exercise your rights either by sending a written request to INGETEAM, to the postal address indicated in Section 1 or by sending an email addressed to gdpr.ingeteam@ingeteam.com.

Finally, we would mention that you can lodge a complaint with the competent Supervisory Authority (in Spain, the Spanish Data Protection Agency), particularly when you have not obtained satisfaction in the exercise of your rights. You can contact the aforementioned Supervisory Authority through its website: www.agpd.es

APP INGETEAM NEO

Transcribed below is the Privacy Policy applicable to the registration and use as a user of the “Ingeteam NEO” mobile application (hereinafter the “APP”), made available to Internet users by INGETEAM POWER TECHNOLOGY, S.A. as a service associated with the management of the private electric vehicle charging points acquired by each user (hereinafter the “CHARGING POINTS”). 

Who is responsible for the processing of your data?

INGETEAM POWER TECHNOLOGY, S.A., a company with registered office at Zamudio (Bizkaia), Parque Tecnológico, Edificio 106, Pl 2ª,registered in the Companies Register of Bizkaia, volume 5925, folio 31, sheet BI-59310 and with Tax Identification Code (CIF) A-95663852 (hereinafter “INGETEAM”). 

How do we obtain your personal data?

We only process the data provided by you when you register as a user of the APP and/or during your use. The APP does not use cookie files or similar information storage and retrieval technologies during its use. 

What type of personal data do we process?

As a result of the use of the APP, we process the following data categories: 

• Identification and contact details obtained when you register (e.g. name, surnames, email address and phone number).
• Identification codes and passwords as a registered APP user.
• Data relating to charging configuration, control and planning.
• Charging history.

The APP uses the Bluetooth communication functionalities of the mobile terminal on which it is installed to communicate with the charging points associated with the user, and to permit operation. The APP will solely make use of the location and Bluetooth services if the user grants the APP the appropriate permission to do so during the session login, while this does not give INGETEAM access to, or the possibility of processing the said data in any way. If this permission is not granted, then the APP will not use the said data, although some of its functionalities may not be available.  

Likewise, the APP will request permission to access the camera on the mobile terminal solely for the purpose of scanning the charging point QR identification code and associating it with the user. 

What is the purpose and legal grounds for processing your personal data?

We process your personal data for the sole purpose of handling and managing your registration as a user of the APP and the subsequent use of the APP as a service, all based on the contractual relationship established with you in this regard. 

How long will we store your personal data?

Your personal data will be kept while you remain a user of the APP and for as long as necessary for the management of the contractual relationship between the parties, or until you request the erasure of such data at an earlier time. 

Who will your personal data be sent to?

Your data will not be released to third parties. 

INGETEAM uses the IT services of third parties (e.g. VELTIUM SMART CHARGERS, S.L.) who may process your data in its capacity as Data Processor and for the sole purpose of providing its services to INGETEAM. 

On the other hand, we would inform you that VELTIUM SMART CHARGERS, S.L. uses the services of third parties (Sub-processors) based in the United States with regard to the processing of your data (e.g. storage and processing of information). Your data will therefore be subject to international transfer coming under the use of Standard Contractual Clauses for the transfer of personal data to processors based in third countries approved by the European Commission. 

What are your rights when you provide us with your personal data?

You have the following rights with regard to personal data protection: 

• Access to your data: to access your data in order to find out what personal data concerning you are being processed by us.
• Request the rectification or erasure of your data: in certain circumstances, to rectify any inaccurate personal data concerning you and that are being processed by us, or even to request us to erase such data when, among other reasons, the data are no longer necessary in relation to the purpose for which they were collected.
• Request a restriction on the processing of your data: in certain circumstances, to ask us for a restriction on the processing of your data, in which case we can inform you that such data will only be kept for the exercise or defense of legal claims.
• To the portability of your data: in certain circumstances, you have the right to receive the personal data concerning you and that you have provided to us, in a structured, commonly used and machine-readable format and to transmit such data to another data controller .
• To object to the processing of your data: in certain circumstances and on grounds relating to your particular situation, to object to the processing of your personal data. In this case we would stop processing such data unless, due to compelling legitimate grounds, or the exercise or defense of possible legal claims, the data must be retained.

Likewise, you have the right to withdraw consent at any time, without this affecting the lawfulness of processing based on consent prior to withdrawal.  

You may exercise this right by e-mailing a request to gdpr.ingeteam@ingeteam.com. 

Finally, we would mention that you can lodge a complaint with the Spanish Data Protection Agency, particularly when you have not obtained satisfaction in the exercise of your rights. You can contact the aforementioned Supervisory Authority through its website: www.aepd.es 

Additional, we would inform you that INGETEAM has a Cookies Policy that can be accessed through the following link.