Confidentiality and security are core values at CELER PAWLOWSKY, S.L. (CPSL), and because of this we are committed to ensuring the privacy of our clients’ personal data at all times and to collecting only essential information.

Below you’ll find everything you need to know about our Privacy Policy regarding the personal data we collect, including:

• Who processes your data
• Why we request your data
• The legal grounds for processing your data
• How long we store your data
• Who your data is disclosed to
• What your rights are

Who is responsible for processing your data?

Company name: CELER PAWLOWSKY, S.L. (CPSL)

VAT No.: ESB60266798

Adress: Ronda Sant Pere 52, Planta 5, P014 08010, Barcelona (Spain)

Contact email: rgpd@cpsl.com

In addition, we hereby inform you that data may be shared with other companies in the CPSL Group, each acting within the scope of their respective areas of competence, in order to offer you better service and facilitate the ordinary activities of our companies.

The following companies are part of the CPSL Group:

CPSL Documentation & Tools, GmbH

                     BülowBogen Business Center. Heilbronner Strasse 150,  Office #60. 70191 Stuttgart, Germany

VAT No.: DE224408620

CPSL USA Corporation

One Beacon St, 15th floor, Suite #15B135, Boston, MA 02108, USA

Who are the data subjects?

The personal data that is processed belongs to the following data subjects:

• Individuals who have supplied us with their data via any of the forms on the website, for the purpose of making enquiries or obtaining information on our services and activities
• Individuals who have subscribed to our blog
• Individuals who apply to work with us
• Students who apply for internships in CPSL
• Individuals who want to join CPSL’s team of external partners

For what purposes and on what legal grounds do we use personal data?

At CPSL, we process personal data in order to respond to requests for information or to answer your enquiries.

This personal data will be processed for the legitimate purposes described below.

• Responding to information or contact requests

At CPSL, we will use the contact information provided to answer requests and enquiries regarding our products and services, which may be made using the form available on the website or by sending an email to one of the contact addresses listed.

Legal grounds:

CPSL’s legitimate interest in processing data, taking into consideration the reasonable expectations of the data subjects who expect to receive a response to their enquiries

Explicit consent, which is expressed by sending data via the form provided for this sole purpose

•  Managing subscriptions to CPSL’s blog

CPSL will process the contact information provided for the purpose of managing blog subscriptions and sending messages that contain information on new blog content.

Legal grounds:

Explicit consent, which is expressed by sending data via the form provided for this sole purpose

• Selecting candidates who apply to work at CPSL

The personal data of people who apply to work at CPSL will be processed for the purposes of carrying out the selection process and validating applications for open positions.

Legal grounds:

Processing which is necessary to perform a contract to which the data subject is party or in order to take steps at the data subject’s request prior to entering into the contract

CPSL’s legitimate interest in managing job applications for open selection processes, taking into consideration the reasonable expectations of the data subjects who are participating in these processes

Explicit consent, which is expressed by sending data via the form provided for this sole purpose

The personal data of people who apply to undertake internships in CPSL will be processed for the purpose of validating their applications.

Legal grounds:

CPSL’s legitimate interest in managing applications for internships in CPSL, taking into consideration the reasonable expectations of the data subjects who are participating in any such processes

Processing which is necessary to perform a contract to which the data subject is party or in order to take steps at the data subject’s request prior to entering into the contract

Explicit consent, which is expressed by sending data via the form provided for this sole purpose

• Applications to join CPSL’s team of external partners

The personal data of individuals who wish to join CPSL’s team of external partners will be processed for the purpose of confirming that they possess the skills and abilities required to provide the service in question.

Legal grounds:

CPSL’s legitimate interest in evaluating applicants who wish to join CPSL’s team of external partners, taking into consideration the reasonable expectations of the data subjects who are participating in these processes

Processing which is necessary to perform a contract to which the data subject is party or in order to take steps at the data subject’s request prior to entering into the contract

Explicit consent, which is expressed by sending data via the form provided for this sole purpose

In addition to the purposes set out above, CPSL may also process personal data for other reasons. In such an event, the data subject will receive all information necessary regarding the processing of this data, and CPSL will request the subject’s consent should it be required.

How long will CPSL store the data?

As a general rule, data will be stored for as long as is necessary to fulfil the purpose for which it was requested and to enable any liability arising from this purpose or from data processing to be determined.

This means, inter alia, that CPSL will store data subjects’ personal data for as long as their relationship with us lasts, and, if applicable, for as long as is necessary for the establishment, exercise or defence of legal claims, or to fulfil legal obligations under the applicable law.

With respect to the data of candidates who apply to work with us, whether this entails participating in selection processes, undertaking internships or providing services as a partner, said data will be stored for a maximum period of 1 year if their application is not successful during this time or if the data subject has not consented to storage of the data for a longer period.

After this period has lapsed, CPSL undertakes to cease all processing of personal data and to destroy, block or anonymise this data to the maximum extent possible in view of the purpose for which it is stored.

Who will the data be disclosed to?

Personal data will only be transferred to third parties if it is necessary to do so in order to respond to a request, if there is a legal obligation to do so, or if the data subject has consented.

Notwithstanding the foregoing, data may be shared between the various companies that comprise the CPSL Group. The disclosure of data between the companies in the group is based on a legitimate interest in transferring personal data within the business group for internal administrative purposes. Nevertheless, under no circumstances will the data of EU citizens be disclosed to companies outside of the EU.

We may also disclose data to national or international companies that provide us with services associated with the company’s ordinary and administrative activities, in their capacity as data processors and in connection with the provision of services. These companies may include, inter alia, providers of services such as email, web hosting, server hosting, SaaS management applications, cloud file storage and other services.

The provision of these services may involve the processing of personal data by companies located in countries outside of the European Economic Area (international transfers of data). However, this will only be done if the country in question ensures an adequate level of protection or, for organisations in the USA, with companies that are accredited under the EU-US Privacy Shield. Commission Implementing Decision (EU) 2016/1250 of 12 July 2016.

What rights do data subjects have when providing us with their data?

At any time, data subjects may exercise their right to access, rectify, delete or port the personal data processed by CPSL, or the right to object to or restrict the processing of said data.

These rights may be exercised free of charge by data subjects or, where applicable, by their legal representatives, by sending a signed written request and a copy of the subject’s National Identity Card or an equivalent document that provides valid proof of ID, to:

• Requests made by email: rgpd@cpsl.com
• Requests made by post: Gran Vía, 8-10, 3º 4ª, 08902 Hospitalet de Llobregat, Barcelona (Spain)

Legal representatives must provide a written document as proof of their power of representation, as well as a copy of their National Identity Card or an equivalent document that can attest their status.

In addition to the rights set out above, the data subject also has the right to withdraw consent at any time using the procedure described above, without affecting the lawfulness of data processing carried out before consent is withdrawn. CPSL may continue to process the data subject’s personal data to the extent permissible under the applicable law, or for as long as there are any other legal grounds for doing so.

Specifically, with respect to subscriptions to our blog, data subjects have the right to withdraw consent at any time by notifying CPSL that they no longer wish to receive the associated communications. To this end, the data subject may either withdraw consent in the manner described above, or use the link provided in each commercial communication to unsubscribe from the electronic mailing list.

CPSL reminds data subjects that they have the right to lodge complaints with the relevant authority, i.e. the Spanish Data Protection Agency (Agencia Española de Protección de Datos).

Updating of your data

In order for us to keep your data up to date, it is important that you notify us whenever any of the data has changed. Otherwise, we cannot be held responsible for the accuracy of the data or for any repercussions that processing it may have.

Security of data processing and safekeeping

CPSL hereby declares that it has taken appropriate technical and organisational measures to ensure and to be able to demonstrate that processing is carried out in accordance with the applicable law while ensuring that data subjects’ rights are protected.

To this end, it has implemented a Personal Data Protection Management System to identify and apply the technical and organisational measures at its disposal to prevent the loss, misuse, alteration, unauthorised access to or theft of data provided by users, without prejudice to warnings that internet security measures are not infallible.

Use of cookies

Like most of the websites on the internet, this website uses cookies to improve the user experience. In our Cookies Policy you’ll find information about what cookies are, what type of cookies this website uses, how to disable cookies in your browser and how to specifically disable the installation of third-party cookies.

Please read our Cookies Policy carefully before continuing to use our website.

Changes to the Privacy Policy

CPSL may make changes to its Privacy Policy at any time, in accordance with the applicable law. In any event, you will be duly notified of any changes that are made to the Privacy Policy, in order to inform you of changes to the processing of your personal data and, if required under the applicable law, to enable data subjects to confirm their consent.