Ethical Channel Privacy Policy

1. Identification and contact details of the Controller

The personal data that you provide us through the Ethical Channel, as well as others that are collected during the management of your consultation or complaint will be treated by Lorca Telecom Bidco S.A. with CIF: A88585906 and registered office at Avenida de Bruselas, 38, Alcobendas, 28108 Madrid

2. What do we process your personal data for?

Your personal data are processed to manage complaints or consultations submitted regarding irregularities, non-compliance or infringement of policies, codes and any legislation or regulations applicable to any company of the MASMOVIL Group or other companies with which the Group maintains some type of commercial relationship.

Access to the data contained in the Ethical Channel is limited exclusively to the persons who at any time carry out the compliance functions, and, where appropriate, to those in charge of the treatment that may be designated for this purpose, in accordance with the provisions of section 4.

Personnel with functions of management and control of Human Resources may access when it is necessary for the adoption of disciplinary measures that could be appropriate.

3. What is the legitimation for the processing of your personal data?

Lorca, as the parent company of the MÁSMÓVIL Group, is responsible for defining and monitoring the Group’s Criminal Risk Management model in order to ensure compliance with the commitments assumed by the Group in its Crime Prevention Policy and in its criminal compliance and anti-bribery system.

We will process your personal data on the basis of the legitimate interest of ensuring compliance with any internal regulations: policies, codes and regulations of defined actions, and any general or sectoral legal provision, within the companies that make up the MÁSMÓVIL Group or in the action of third parties that have a commercial relationship with them, in accordance with the provisions of Article 24 of the Data Protection Law.

4. To which recipients are your personal data communicated?

In the event that the complaint you submit ends with the initiation of a judicial or administrative procedure, the Judges and Courts or the competent authority may have access to this information.

The group’s information and technology service providers who need to access them to provide the contracted service will have access to the personal data. Likewise, we inform you that we will not carry out any international transfer of your personal data.

5. How long do we keep your personal data?

The data incorporated into the complaints or consultations that are sent will be kept in this system for the time necessary to decide whether it is necessary to initiate an investigation into the alleged complaint, without this period extending more than three months from the time the complaint is filed. In the event that it is decided that an investigation should not be initiated, or that this deadline is met, the data will be deleted from the Ethical Analysis system. They may be maintained to prove compliance with the obligation to have a complaints channel. In any case, complaints that have not been processed will be anonymized.

In the event that it is decided that an investigation should be initiated, the data will be deleted from the Ethical Channel being processed in the corresponding system. The information will be kept in said systems for the time strictly necessary for the good end of the investigation, as well as for the processing of the corresponding administrative and judicial procedures and the adoption, where appropriate, of disciplinary measures. Once its processing is completed, the data will be kept blocked in order to prove compliance with the obligation to have a complaints channel.

6. What are your rights?

We inform you that you can exercise the following rights:

  1. right of access to your personal data;
  2. right to rectification of any inaccurate personal data;
  3. right to deletion of your personal data, where possible;
  4. right to request the limitation of the processing of your personal data when the accuracy, legality or necessity of the processing of the data is doubtful, in which case, we may keep them for the exercise or defense of claims.
  5. right to object to the processing of your personal data.
    You can exercise your rights at any time by accompanying a copy of your DNI or other document that proves your identity, and free of charge in the following ways:

    1. By sending an email through the address indicating “Exercise of ARCO rights” and specifying the right you wish to exercise and your identification data.
    2. By sending a written request to the Compliance Officer of the MASMOVIL Group, at the following address: Avenida de Bruselas, 38, Alcobendas, 28108 Madrid, visibly including the reference “Exercise of ARCO rights” and indicating the right you wish to exercise and your personal data.

On the other hand, we inform you that you can contact our Data Protection Officer directly through the email or file a claim before the Spanish Agency for Data Protection if you consider that an infringement of the legislation on data protection regarding the processing of your personal data has been committed.

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