1. Inclusion of personal data in the IQL files

This privacy policy (“policy”) applies to the processing of personal data by IQL in connection with any:

• “client services”: provision of products and services by IQL to actual and prospective clients;
• “supplier services”: provision of products and services to IQL by suppliers or service providers;
• “recruitment activities”: provision of the personal data of a candidate or individual for a position at IQL other than through IQL’ usual recruitment process.

Pursuant to 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 the implementing regulations thereof, you are hereby informed that the personal data you provide will be processed for the purpose of providing you with the requested information about our services or, where appropriate, to manage the contracting of our services and the implementation of your projects through our Website.

This policy aims to give you information about how IQL collects and processes your personal data. It is important that you read this policy together with any other policies we may provide on specific occasions when we are collecting or processing your personal data, so that you are fully aware of how and why we are using your personal data. This policy supplements the other policies and is not intended to override them

2. Who is the controller for the personal data processed?

This policy is issued on behalf of IQL as controller. Unless we notify you otherwise IQL is the controller for your personal data.

If you have any questions about this policy, including any requests to exercise your rights, please contact us using the contact details set out below:

Compliance Officer
Pol. Ind. Pla del Camí
Av. De la Indústria, 7
08297 Castellgalí, SPAIN

Email: iql.web@iql-nog.com
Telephone: +34 93 875 88 40

We recognise that the use and disclosure of personal data has important implications for us and for the individuals whose personal data we process. Most of our offices operate in countries which regulate the use, and impose restrictions on overseas transfers, of personal data. Our privacy policy is available here . You can request a copy of this policy at any time by contacting us at iql.web@iql-nog.com.

3. Purpose of the information collected through the Website

The purpose of the information collected through the Website is to allow the correct provision of our services and to facilitate the fulfilment and execution of the contractual relationship, to carry out, where appropriate, the management of charges for services, and to perform internal studies on the effectiveness of the website, marketing, advertising and sales.

By filling out the forms on our Website or any type of information request sent to IQL from the emails provided on our Website, the User gives their consent to the processing of their personal data to address their queries.

The User who contracts our services, by accepting this Privacy Policy, expressly consents to IQL sending communications regarding the development and purpose of the Website, information about offers, as well as any other type of promotional information related to our activity.

4. Transfer of personal data by IQL

IQL will not give or transfer to any third party the personal data collected through the Website, except when it is expressly authorized to do so by legal obligation or is absolutely essential for the proper execution of the contracted services.

Likewise, IQL commits to keep the due professional secret and to establish the necessary technical and organizational measures to safeguard the information in accordance with the requirements established in the aforementioned Regulations.

5. Third party data

If for any reasons a client provides IQL with third party data such as their name and identification of clients or users of their web pages, in this case, it will be the responsibility of the IQL’s client to obtain the corresponding authorization from each of the affected parties, without prejudice to the communications that IQL may perform, if necessary, to confirm said authorization. The client must keep IQL harmless from any damages, including fines, that it may suffer as a result of not obtaining such authorization.

6. Security measures

IQL expressly assumes the obligation to implement the necessary security measures, applying the appropriate techniques to ensure an adequate level of security based on the analysis of risks. IQL guarantees the confidentiality, integrity, availability and permanent recovery of the processing systems and services.

7. Personal data

We collect, use, store and transfer different kinds of personal data about you. We have grouped together the following categories of personal data to explain how this type of information is used by us. These terms are used throughout this notice:

• “Identity Data”: including your first name, middle names, maiden name, last name, marital status, title, date of birth, passport number, photographic identification and gender;
• “Contact Data”: including your billing address, delivery address, email address and telephone number;
• “Services Data”: including details about payments to and from you and other details of services you have purchased from us or we have purchased from you;
• “Profile Data”: including your usernames and passwords, purchases or orders made by you, your interests, feedback and survey responses;
• “Usage Data”: includes information about your use of our website, our client knowledge portal, our local area networking facilities (including WiFi) and similar electronic services. Additional information about personal data we process based on your usage of our website is available in the privacy notice for our website (which can be accessed from the privacy section of our website);
• “Technical Data”: includes information collected when you access our website or client knowledge portal, your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you are using;
• “Marketing and Communications Data”: including your marketing and communication preferences. We also track when you receive and read marketing communications from us and which of our events you attend, which information we use to improve our marketing services, provide you with more relevant information and improve the quality of our marketing materials. Additional information about the personal data we process in connection with marketing is included with the marketing communications we send you;
• “Professional Information”: including your job title, email address, phone number and addresses;
• “CCTV Data” including CCTV footage and other information obtained through electronic means such as swipecard records.

The personal data of users who have given their express consent for the sending of commercial communications will be kept as long as they do not object to such processing.

8. How your personal data is collected

We use different methods to collect personal data from and about you, including through the channels set out below.

Direct interactions: You give us your personal data in your direct interactions with us. Such personal data includes Identity Data, Contact Data, , Services Data, Profile Data, Usage Data, Technical Data, Marketing and Communications Data, Professional Information, CCTV Data and/or Professional History which you give us from time to time (i) by filling in forms on our Website; (ii) through other electronic platforms which we offer or which we have agreed with you to use, (iii) by corresponding with us by email or post, (iv) by speaking to us in person or over the telephone, or (v) whilst visiting our offices.

Website, cookies and marketing: You give us your personal data, which includes Profile Data, Usage Data, Technical Data, Professional Information and/or Marketing and Communications Data, when you use our Website or review the publications or marketing we send you. Please refer to the privacy and cookie policy for our Website.

Third-party sources: We receive Identity Data, Contact Data, Financial Data, Professional Information and Special Categories of Personal Data about you from third parties, when we:

• provide our client services or other parties send us your personal data to enable the provision of those service;
• conduct our “know your customer” and other background checks;
• you provide your personal data to a third party for the purpose of sharing it with us, for instance recruitment agencies and consultants may provide your personal data to us for recruitment activities; and
• we interact with governmental or regulatory bodies or other authorities in relation to you or on your behalf.

9. Social Networks

By following our social network profile you expressly consent to the processing of your personal data in accordance with their privacy policy. You also expressly consent to the access by IQL to the processing of your data contained in the list of friends and that the news published about the services offered by IQL will appear on your wall. In accordance with REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT, we inform you that the personal data of the followers of IQL in social networks will be incorporated into a file owned by IQL with the purpose of keeping you informed through social networks about its services.

Your request to connect necessarily implies your consent for the above mentioned processes.

The publication of comments and content in social networks will become public information, so users should be especially careful when they decide to share their personal information. IQL is not responsible for the information that users incorporate into the page. However, persons whose personal information is published or included in comments may request IQL to cancel the same.

10. Rights of access, rectification, deletion and opposition

At any time, you can exercise your rights of access, rectification, deletion, opposition, limitation of the processing of your data, or directly exercise the right to the portability of the same. All of this must be done in writing, accompanied by a copy of an official document that identifies you, addressed to iql.web@iql-nog.com -for more detail please see Section 2 above-.

Alternatively, the exercise of these rights can be done by writing of the same characteristics sent by mail to the registered office of IQL that appears in the web page putting as reference “RGPD Rights”.

You may raise your concerns with your local data protection authority directly, without going through our internal procedure. However, we would encourage you to contact us in the first instance as we aim to promptly, efficiently and satisfactorily resolve any concerns or complaints you may have in relation to IQL’s processing of your personal data.

11. Change of purpose

We will only use your personal data for the purposes for which we collected it as detailed in Section 7 and Section 12, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at iql.web@iql-nog.com.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

12. Changes to the policity or to your personal data

The first version of this notice was issued in March 2021 and this policy was last updated on the “as amended on” date (if any) on the cover page of this notice. Any prior versions of this notice can be obtained by contacting us at iql.web@iql-nog.com.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. If you wish to update your personal data, please contact us at iql.web@iql-nog.com.

13. International transfers

When we share your personal data within IQL, this involves transferring your personal data outside the European Economic Area (“EEA”).

In some cases, the parties who we use to process personal data on our behalf are based outside the EEA, therefore their processing of your personal data will involve a transfer of such data outside the EEA. Similarly, in the course of advising clients based outside of the EEA, we may be required to share matter-relevant personal data with them. Where this is the case we will only share the minimal amount of personal data necessary for the purpose of processing and, where possible, we will share the personal data in an anonymised form.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; and
• where we use certain service providers, we may use specific contracts approved by the European Commission which gives personal data the same protection it has within the EEA.

Please contact us at iql.web@iql-nog.com if you would like further information about the specific mechanism used by us when transferring your personal data out of the EEA.