In order to receive and process your complaint, you must confirm that you have read this Privacy Notice. If you do not accept the terms and conditions in accordance with what is provided in the notice, you will not be able to make the complaint.
Please note that this channel is not intended for reporting emergencies.
The complaints channel is managed by BASE TECHNOLOGY & INFORMATION SERVICES S.L.U (hereinafter, BASETIS), using the ithikios platform, owned by Digital Products Development SL, a company specialized in offering internal complaints channel management systems for companies. It maintains a contractual relationship with BASETIS as data processor for the purpose of receiving, storing and sending communications to the BASETIS Compliance team. Ithikios guarantees security and confidentiality for the purpose of the contracted processing.
This Channel is an instrument established within the Compliance Management System implemented by BASETIS, and is governed by a management and investigation procedure that contemplates the provision and protection of the rights and guarantees of all the parties involved in the complaint process and subsequent investigation.
Any of the different BASETIS interest groups (employees, users, customers, suppliers...) can access and use the Ethical Channel by committing to its good management, in accordance with the Rules of Use and Operation of the Channel. Once the channel is accessed, and prior to the configuration of the communication to be made, the user will find the Rules of Use and Operation of the Channel, as well as Privacy and Data Protection Policy of the company.
Below, we will show you the basic information on how we treat your personal data:
| Data Controller | BASE TECHNOLOGY & INFORMATION SERVICES S.L.U (BASETIS) with registered office at Passeig de Gràcia, 92, 2ª, 08008 and with NIF B-65208183. It is registered in the Mercantile Registry of Barcelona. |
| Data Protection Officer | You can contact via email: [email protected] |
| Data processed and origin | They are: - Your contact details, if you provide them (name and surname, e-mail, telephone). - Name and position of the persons to be reported in the communication. - Information (regardless of its nature) of the facts reported. |
| Purpose of the treatment and legitimation | The legal basis that legitimizes the treatment of your data resides in the fulfillment of a mission carried out in the public interest, such as the prevention of criminal offenses and the criminal liability of legal entities, by virtue of which is provided in article 24 of the Organic Law on Data Protection and Guarantee of Digital Rights. For its part, the treatment of communications or complaints concerning ethical principles and standards is carried out by virtue of the legitimate interest that BASETIS has in its capacity as data processor; and if the facts reported affect any BASETIS employee, the authority of the entity to manage its workforce and, where appropriate, to adopt the appropriate disciplinary measures within the framework of the employment contract signed between the parties. BASETIS informs you that your personal data will be collected and processed for the purpose of: ● Analyzing, processing and investigating the facts communicated confidentially. ● Manage the query you submit. ● Exchange information with the aim of complementing your request. ● Interview you to clarify the facts communicated, if applicable. ● Adopt the relevant corrective measures, ● If necessary, inform you about the result of the procedure. Our legitimate interest is to ensure compliance with applicable policies and rules and/or legislation. |
| Recipient of transfers | Those who are necessary in accordance with the Law, the service providers in their capacity as data processors. Likewise, this information will only be communicated to third parties when it is essential for the investigation or the sanctioning of the facts reported, when a law so provides or with the prior consent of those affected. Personal data will not be transferred to other third parties, except legal obligation. |
| International transfer recipient | All those derived from the processing of the communication itself as well as those derived from our relationship with the provider that manages the Ethical Channel with the guarantees set out in the Privacy Policy. |
| Conservation period | The data will be kept for the time necessary to decide whether to initiate an investigation into the facts reported. In any case, three months after the data have been entered, the data will be deleted from the reporting system. And if it is necessary to keep the data in order to continue the investigation, they may continue to be processed in a different environment by the body of the entity responsible for the investigation. Communications that have not been followed up may only be recorded in anonymised form. |
| Rights of interested parties | Access, rectification, deletion or forgetting, limitation, portability, opposition, and submit claims to the relevant control authorities. |