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We care about your privacy
At MUTUALIDAD GENERAL DE LA ABOGACÍA, MUTUALIDAD DE PREVISIÓN SOCIAL A PRIMA FIJA (hereinafter collectively and indistinctly referred to as “Mutualidad”, “we”, “our” or “us”), we consider the privacy of individuals to be important, both for visitors to our website https://www.mutualidad.com (hereinafter, the “website”) and for any other affected parties who provide us with information through it, whose data are processed by Mutualidad as part of the provision of services (hereinafter and jointly, “you” or the “user”, and in the plural, “you all” or the “users”). In this regard, Mutualidad undertakes to process your data in accordance with the applicable personal data protection regulations in force at all times. Specifically, Mutualidad will comply with the provisions of: 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, repealing Directive 95/46/EC; Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights; and any other related regulations in force at any given time.
On this basis, Mutualidad informs you of its Privacy Policy, with the aim of making users aware of how their data are processed, as well as of the fundamental principles on personal data protection that it applies. Nevertheless, certain services that may be offered on the website in the future may contain specific terms of use with particular provisions regarding personal data protection, which shall prevail over this Privacy Policy.
In connection with the above, we encourage all users to read this Privacy Policy carefully in order to understand the rules and practices we have established to protect personal data and to better understand our relationships with third parties who may have access to such data.
In any case, the user is solely responsible for the information provided on the website, and if in the future Mutualidad wishes to use such information for purposes other than those mentioned, we will inform you of these new purposes and request your consent, where required.
Who is the Data Controller for your data?
Contact details of the data controller: MUTUALIDAD GENERAL DE LA ABOGACÍA, MUTUALIDAD DE PREVISIÓN SOCIAL A PRIMA FIJA, with NIF number V-28/024149 and registered address at C/ Francisco Silvela, 106-28002, Madrid (Spain) and contact email buzon@mutualidad.com, contact details of the Data Protection Officer (DPO): proteccion.datos@mutualidad.com.
For what purpose do we process your personal data and on what lawful basis?
Under the current Privacy Policy, “personal data” is considered to be any information that identifies you or can be used to identify you, such as your name, address, phone number, or email address.
The personal data provided by users during browsing may be processed for the following purposes:
| Purpose | Legal basis |
|---|---|
| Respond to inquiries, requests, or information demands made by users and follow up on them. | User consent when submitting the request (Article 6.1.a GDPR). |
| In the online contracting process, information will be used to uniquely identify the applicant, assess the feasibility of the insurance contract based on the provided information, and, if applicable, manage the signing of the contract and the subsequent management of the contracted insurance. We remind you that all our contracts include information on personal data processing linked to contract management. | Performance of a contract to which the data subject is party or pre-contractual measures (Article 6.1.b GDPR). |
| If the user provides their CV, the data will be used to manage recruitment, assess the candidate’s suitability for a specific job, and include them in a selection process for possible hiring. | Performance of a contract or pre-contractual measures (Article 6.1.b GDPR). User consent when sending the CV (Article 6.1.a GDPR). |
| Manage participation in promotions, raffles, or contests, deliver prizes, and fulfill promotional obligations. Each promotion or contest will have its own legal terms. | Performance of a contract when the promotion is linked to it (Article 6.1.b GDPR). User consent when participating (Article 6.1.a GDPR). |
| Personalize and improve website tools and functionalities, and ensure proper technical functioning. | Legitimate interest in analyzing data for statistical purposes, system monitoring, and service continuity (Article 6.1.f GDPR). |
| If the user has given consent, send newsletters or other electronic communications about services, activities, updates, collaborations, products, and services of the Mutualidad Group or third parties. | User consent for commercial communications (Article 6.1.a GDPR). |
| Social media advertising targeting users with services similar to those contracted. Email addresses may be used for list-based matching on social networks, without the company accessing user data on those platforms. | Legitimate interest in promoting products and services via social media targeting (Article 6.1.f GDPR). |
| Send surveys or actions to assess service quality and user satisfaction. | Legitimate interest in improving company activities (Article 6.1.f GDPR). |
| Comply with legal obligations. | Legal obligation compliance (Article 6.1.c GDPR). |
When the user is a member and accesses their personal area on the website, the data provided or collected may also be used for the following purposes:
| Purpose | Legal basis |
|---|---|
| Enable use of the personal area services, including viewing contracted products, requesting new products, making contributions, and modifying contracts. | Consent upon registration and/or execution of a contract (Articles 6.1.a and 6.1.b GDPR). |
| Provide micro-savings services, including linking bank accounts/cards, savings rules, periodic contributions, and tracking goals. | Legal obligation compliance and contract execution (Articles 6.1.c and 6.1.b GDPR). |
| Provide the financial planning service “My Financial Health,” including analysis of income/expenses, financial insights, and recommendations. | Contract execution and legal obligations (Articles 6.1.b and 6.1.c GDPR). |
| Compliance with Anti-Money Laundering Law (Law 10/2010), including risk verification and due diligence obligations. | Legal obligation compliance (Article 6.1.c GDPR). |
| Respond to customer inquiries and requests. | Contract execution or pre-contractual measures (Article 6.1.b GDPR). |
| Manage user consent regarding profiling and marketing communications, and allow data access/modification. | User consent (Article 6.1.a GDPR). |
| Keep users informed about products, services, and updates via the website. | Legitimate interest in keeping customers informed (Article 6.1.f GDPR). |
Additionally, when using the telephone contact channel, you should be aware that data collected through recorded calls made to customer service numbers (or calls made by Mutualidad or authorized companies) may be used for the following purposes:
| Purpose | Legal basis |
|---|---|
| Proof of contracting. | Contract execution or pre-contractual measures (Article 6.1.b GDPR). |
| Improve service quality, manage claims, and verify user satisfaction. | Legitimate interest in improving company operations (Article 6.1.f GDPR). |
How long do we keep your personal data?
Mutualidad processes your personal data for the period necessary to comply with the purposes established in this Privacy Policy, as well as to retain your personal information in compliance with the provisions of applicable laws and regulations.
The criteria we follow for this are determined by:
- The purpose of the data collected and the fulfilment of that purpose.
- Mandatory retention periods in accordance with contractual and regulatory requirements.
- Longer retention periods than those required by regulation when the conditions to extend the period are met.
Currently, the data of members will be retained for the maximum period established by the Anti-Money Laundering Law. In the event that the contract is not formalised, the data provided will be kept blocked for the period legally required to address any potential liabilities arising from the processing.
Please note that once the data has been deleted, it may still be kept blocked for defence against possible claims during the statutory limitation period for legal actions.
Who may your data be disclosed to?
Depending on the purposes for which personal information is collected, the following persons and entities may have access to such information:
- Authorised personnel of Mutualidad or of the entities within its corporate group who, within the framework of internal organisation and the provision of services linked to the contractual relationship, act on behalf of Mutualidad and under its instructions, as well as third-party providers who act as data processors with whom the corresponding contracts have been signed in accordance with Article 28 of the GDPR.
- Public administrations, regulatory authorities or other third parties in accordance with applicable laws.
- Other companies that form part of the Mutualidad Group, to the extent that such data transfer is provided for or authorised by applicable regulations.
- Third parties providing services related to the insurance contract: reinsurers and experts.
- Third parties (service providers who process information as data processors, under the instructions of Mutualidad), provided that the necessary measures have been taken to ensure that such data sharing complies with applicable data protection regulations.
- Confirma Sistemas de Información, S.L., with Tax ID B-86303757 and registered office at Avda. de la Industria, 18, Tres Cantos (28760) Madrid, for the purpose of detecting irregularities, preventing fraud and complying with legal obligations regarding anti-money laundering and counter-terrorism financing.
- In the context of micro-savings and financial planning services, personal data related to linked bank accounts and cards may be sent and received through the provider MORPHEUS AIOLOS S.L. (Afterbanks). The use of this provider’s services must be expressly authorised by the user.
We will not sell or disclose to third parties any personal information or data that you have provided on our website that could identify you directly or indirectly.
What are your rights when you provide us with personal data?
Users may request the following rights:
- Right to request access to personal data: you may ask Mutualidad whether it is processing your data, its purpose and origin, and if so, access it.
- Right to request rectification if the data is inaccurate, or to complete any incomplete data we hold.
- Right to request erasure of your data.
- Right to request restriction of processing: in this case, we will only retain the data for the exercise or defence of legal claims.
- Right to object to processing: Mutualidad will stop processing the personal data, except where it must continue to be processed for legitimate reasons or for the exercise or defence of possible claims.
- Right to data portability: if the user wishes their data to be processed by another data controller, Mutualidad will facilitate the transfer of their data to the new controller.
- Right not to be subject to a decision based solely on automated processing of personal data.
If you have given consent for any specific purpose, you may withdraw it at any time, without affecting the lawfulness of processing based on consent prior to its withdrawal.
You may request the exercise of the above rights by emailing proteccion.datos@mutualidad.com or by sending a postal request to C/ Francisco Silvela, 106-28002, Madrid (Spain).
In any case, once the user exercises their right to erasure, all personal data linked to their account, as well as any information and content included in their profile, will be deleted.
You may use the templates and forms relating to the above rights by visiting the official website of the Spanish Data Protection Agency.
Complaint to the Supervisory Authority: If you believe that Mutualidad is processing your personal data improperly, you may lodge a complaint with the Spanish Data Protection Agency.
Minor’s data
The contact form and informational material generated by Mutualidad are intended for adult law students or professionals. In any case, if parents or legal guardians believe that their children or dependents have submitted personal data, please contact us by sending an email to proteccion.datos@mutualidad.com
How did we obtain your data?
We obtain your personal data from you through forms available on our website, during the application process for any of our products, or from Confirma Sistemas de Información, S.L., when consulting you for compliance with our obligations under anti-money laundering regulations and to detect irregularities, thereby preventing and avoiding possible fraud attempts.
If you have linked your bank details in order to use the micro-savings service and/or financial planner, the provider MORPHEUS AIOLOS S.L. (Afterbanks) will provide us with the necessary data for the provision of the service.
International transfers
Mutualidad, through its providers, carries out transfers of personal data outside the European Economic Area (EEA). These transfers are made in compliance with applicable data protection laws.
In particular, the providers with whom Mutualidad works comply with one of the following requirements: i) data processing takes place in a territory that ensures an adequate level of protection according to the European Commission; ii) the provider has implemented binding corporate rules; or iii) a contract based on standard contractual clauses has been concluded with the provider.
Regardless of where your personal data is collected or processed, Mutualidad ensures that service providers maintain appropriate technical and organisational security measures to protect your information.
Direct marketing
We will not use users’ personal data for direct marketing purposes without a valid legal basis.
If at any time you decide to stop receiving commercial or promotional information from Mutualidad by any means, including social networks, you may, free of charge and without providing any justification, unsubscribe from direct marketing campaigns and object to the future processing of your personal data for such purposes by emailing us at proteccion.datos@mutualidad.com or by using the unsubscribe procedure provided in any promotional message you receive from Mutualidad.
Please note that even if you choose not to subscribe or unsubscribe from promotional emails or newsletters, we may still need to contact you regarding important non-commercial information, such as troubleshooting, error detection and prevention, or in general to comply with the Legal Notice and/or Terms and Conditions of the website, as well as any communications necessary to fulfil our legal obligations as a mutual entity towards our members.
Automated decision-making
We will not use automated decision-making processes, including profiling, unless we have a lawful basis that allows us to do so.
In the context of a contract application, data may be automatically cross-checked with the database of Confirma Sistemas de Información, S.L.
Profiling will be carried out using the basic data provided and data collected during website browsing when the website is used. Data collection will be carried out in an automated manner and the processing will involve human intervention. Under no circumstances will sensitive data be used for profiling purposes. The authorisation granted does not affect the cookie settings that the user may configure while browsing the website, which will be respected at all times.
The sole purpose of profiling is the personalisation of commercial communications, with no other effect on your relationship with us. Regarding commercial communications, please note that all of them include an unsubscribe option, so at any time, if you change your mind, you may exercise your right to object by using this option, and profiling will cease to have effect.
How do we protect your personal data?
Mutualidad maintains security levels for the protection of your data appropriate to the different personal data processing activities it carries out and to the sensitivity of such data, and has established all technical means within its reach to prevent the loss, misuse, alteration, unauthorised access to and theft of the data that the user provides through the website.
In any event, Mutualidad will adopt appropriate technical and organisational measures, both when designing the data processing system and at the time of the processing itself, in order to preserve security and prevent unauthorised processing.
Confidentiality
The professionals working at Mutualidad who are involved in any way in the services provided to the user are committed not to disclose or make use of the information to which they have had access. In all cases, the information provided by the user will be considered confidential and may not be used for purposes other than those communicated. In this regard, we undertake not to disclose or reveal information, except where the user’s authorisation has been obtained or where disclosure is required under the applicable regulations.
Social Media
Mutualidad has a presence on some of the main social networks on the Internet, where it acts as data controller in relation to the data published by Mutualidad. Specifically, these are the following:
- Facebook: https://www.facebook.com/MutualidadAbogacia
- Twitter: https://twitter.com/MutuaAbogacia
- YouTube: https://www.youtube.com/channel/UCI3b2kvnOZ2mBHyBnqV2_zA
- Google Plus: https://plus.google.com/+mutualidadabogacia
- Instagram: https://www.instagram.com/mutuaabogacia/
- LinkedIn: https://www.linkedin.com/company/mutualidad-de-la-abogaca?trk=top_nav_home
Mutualidad will process data on each social network in accordance with the rules established by each platform. Therefore, and unless otherwise stated by Mutualidad, we may inform our followers on the relevant social network about our activities, events, and other related topics, including follower support, through the channels provided by the social network itself.
Special categories of personal data
We will not collect or process any particularly sensitive personal data or any personal data included within the special categories of personal data of users, unless we are legally authorised to do so or have the explicit consent of the data subject. Special categories of personal data refer to information relating to race or ethnic origin, political opinions, religious or philosophical beliefs or other beliefs of a similar nature, trade union membership, genetic data, biometric data for the sole purpose of identifying a natural person, data concerning health, sex life or sexual orientation.
Policy on children’s use
This website is not designed for or directed at persons under eighteen (18) years of age without the authorisation of their parents or legal guardian. In this regard, we do not knowingly collect information from such persons. In any event, if parents or legal representatives consider that their children have sent us personal data without their consent, please contact us by writing to proteccion.datos@mutualidad.com
Links to other websites
Mutualidad websites contain links to other websites that we consider may be potentially useful and informative for you. However, please note that we do not endorse or recommend the content or services of such websites, nor are we responsible for their privacy policies. We recommend that you take note of and read the privacy policies of all the websites you visit. Please remember that the provisions of this Privacy Policy apply only to the data collected and/or processed by Mutualidad.
Changes
We will only use your personal data as set out in the Privacy Policy in force at the time we collect your personal data. Mutualidad reserves the right to modify this Privacy Policy at any time by publishing such changes on our website, and we therefore recommend that you review it each time you access the website. If at any time we decide to use personal data in a manner different from that stated at the time of its collection, you will be informed appropriately. And, where necessary, at that time you will be given the option to authorise other uses or disclosures of the personal data that you provided to us before the modification of our Privacy Policy.
If any clause of this Privacy Policy is annulled or considered null and void, the remaining provisions shall not be affected and shall retain their full validity and effectiveness, in accordance with the regulations applicable at any given time.