Privacy Policy

This Data Protection Policy is intended to provide data subjects with detailed information regarding the Personal Data Protection Policy of HARMON CORPORATE AFFAIRS, S.L. (hereinafter, “HARMON”), in compliance with the applicable legislation in this area, in particular Regulation (EU) 2016/679 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 (General Data Protection Regulation, hereinafter, the “GDPR”), and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights (hereinafter, the “LOPDGDD”).

The purpose of this Policy is to assist the User in making informed decisions when using the Website and to explain how we will process the personal information provided by the User, whether by sending emails to the email addresses indicated on the Website or by submitting data through the forms made available on it. For these purposes, please note that all fields marked with an asterisk (*) in the forms are mandatory; failure to complete any such field may make it impossible for us to deal with the relevant request.

Te invitamos a que la leas con atención para mantener en todo momento el control sobre tus datos personales.

We invite you to read this Policy carefully so that you may remain in control of your personal data at all times. The User warrants that the data submitted or otherwise provided are true, accurate, complete and up to date, and shall be liable for any direct or indirect loss or damage that may arise as a result of any breach of this obligation. Where the data provided relate to a third party, the User warrants that he or she has informed such third party of the matters contained in this Privacy Policy and has obtained that third party’s prior authorisation to provide his or her data to HARMON for the purposes stated herein.

1. Who is the controller of the User’s personal data?

  • Identity: HARMON CORPORATE AFFAIRS, S.L., a Spanish company registered with the Madrid Mercantile Registry (Registro Mercantil de Madrid), Volume 41373, Folio 40, Section 8, Sheet M-733234, holding Spanish Tax Identification Number (CIF) B-42747626.
  • Postal address: Calle Serrano, 57, 6th floor, 28006 Madrid, Spain.
  • Telephone: +34 917 657 580
  • Email: contacto@harmon.es

2. For what purposes do we process the User’s personal data?

Depending on the type of communication received from the User, or the form through which the User provides us with personal data, HARMON will process such data for the purposes of the full management of:

  • Enquiries, questions, requests for proposals or complaints sent by the User to the email address indicated in our “Contact” section.
  • applications for inclusion in our candidate database, so that candidates may be assessed and taken into account in our current or future recruitment processes, whether by completing the form made available for this purpose on the Website in the “Talent” section (“La Mente-Colmena”) or by sending emails to the Controller (including the personal data contained in the curriculum vitae submitted).
  • applications to participate in our Prometeo training programme for young professionals, by completing the form made available for this purpose on the Website in the “Talent” section (“Programa Prometeo”) (including the personal data contained in the curriculum vitae submitted).
  • requests to enrol in our Alumni Programme in order to receive information about activities and events organised by us, social impact projects in which we are involved, training and networking opportunities, or any initiatives that we may launch, by completing the form made available for this purpose on the Website in the “Talent” section (“Programa Alumni”).
  • requests submitted for the exercise of your rights.

3. What is the legal basis for the processing of the User’s personal data?

The legal basis legitimising and permitting the processing of the User’s personal data, depending on the type of communication received, is as follows:

  • Management of enquiries, questions, requests for proposals or complaints submitted by the User [“Contact” section]: processing is based on the performance of a contract, on the grounds of the contractual or pre-contractual relationship established between the parties, in order to take the necessary steps to respond to, process and manage the enquiry, question, request or complaint submitted to us.
  • Management of applications for inclusion in our candidate database for recruitment processes [“Talent” section (“La Mente-Colmena”)/submission by email]: processing is based on the consent given by submitting such personal data.
  • Management of participation in our Prometeo training programme for young professionals [“Talent” section (“Programa Prometeo”)]: processing is based on the consent given by submitting such personal data.
  • Management of requests to enrol in our Alumni Programme [“Talent” section (“Programa Alumni”)]: processing is based on the consent given when requesting enrolment in the programme.
  • Management of requests to exercise your rights: processing is based on compliance with our legal obligations.

4. How long will we retain the User’s personal data?

Depending on the type of communication received from the User, HARMON will retain personal data as set out below and, thereafter, for such further period as may be necessary for the bringing, exercise or defence of claims, or in order to address any potential liabilities:

  • Management of enquiries, questions and/or requests for information or service proposals submitted by the User [“Contact” section]: the personal data provided will be retained for as long as is necessary to deal with the User’s request.
  • Management of applications for inclusion in our candidate database for recruitment processes [“Talent” section (“La Mente-Colmena”)/submission by email]: the personal data provided will be retained for a maximum period of two years, unless the User indicates otherwise or HARMON considers that such data will not be used in recruitment processes because they do not match the required profile.
  • Management of applications for inclusion in our candidate database for recruitment processes [“Talent” section (“La Mente-Colmena”)/submission by email]: the personal data provided will be retained for a maximum period of two years, unless the User indicates otherwise or HARMON considers that such data will not be used in recruitment processes because they do not match the required profile.
  • Management of participation in our Prometeo training programme for young professionals [“Talent” section (“Programa Prometeo”)]: the personal data provided will be retained for as long as is necessary to deal with the User’s request and for the duration of the User’s participation in the internship programme.
  • Management of requests to enrol in our Alumni Programme [“Talent” section (“Programa Alumni”)]: the personal data provided will be retained for as long as is necessary to deal with the User’s request and until such time as the User requests to be removed from the programme.

5. To whom will the User’s personal data be disclosed?

Personal data will not be disclosed to third parties, save for any data processors that provide HARMON with ancillary services necessary for its ordinary operation, such as hosting providers or providers of internal management tools, and save where disclosure is required to competent authorities acting in the exercise of their powers. Accordingly, the personal data provided by the User through the Website may be disclosed to public bodies, courts and other administrative authorities where we consider such disclosure necessary in order to comply with a legal obligation or for the establishment, exercise or defence of legal claims.

6. What rights does the User have when providing us with personal data?

The User has, and may exercise, the following rights in relation to the personal information provided to HARMON:

  • Right of access: the User has the right to obtain confirmation as to whether HARMON is processing personal data concerning him or her and, where that is the case, to access such personal data.
  • Right to rectification: the User may request that inaccurate data be rectified or incomplete data be completed.
  • Right to erasure: the User has the right to request that we erase or delete his or her personal data in certain circumstances, including where the data are no longer necessary for the purposes for which they were collected, or where the User withdraws consent in relation to processing based on that consent. In the case of withdrawal of consent to receive communications, the User may unsubscribe by clicking the link provided for that purpose in each communication sent.
  • Right to restriction of processing: the User may request, in certain circumstances, that we temporarily restrict the processing of the personal data provided, for example where he or she contests the accuracy of such personal data or objects to the processing, in which case we will only retain the data for the establishment, exercise or defence of claims.
  • Right to data portability: in the case of certain processing operations carried out by automated means, the User has the right to receive the personal data that he or she has provided to us in a structured, commonly used and machine-readable format, and also to request that those data be transmitted to another controller, where technically feasible.
  • Right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos – agpd.es): if the User has any concerns regarding our privacy practices, including the manner in which we have processed his or her personal data, he or she may lodge a complaint, particularly where he or she has not obtained satisfaction in the exercise of his or her rights.

The User may exercise his or her statutory rights before the Controller at any time by means of a written request addressed to HARMON CORPORATE AFFAIRS, S.L. at the addresses indicated in this Privacy Policy (Reference: “Exercise of Rights LOPDGDD”), duly identifying himself or herself and including: the request specifying the subject matter of the application, an address for service, the date, signature and, where appropriate, any supporting documents relating to the request made.