Privacy Policy

The privacy and confidentiality of user information is important to VERDIAN BV and its subsidiaries (hereinafter referred to as the Verdian Group). We are committed to the privacy and security of user information.

We may update this policy from time to time, so please check back frequently.

This Privacy Policy is intended to help you understand:

• Identify who is responsible for the processing of your data;
• which regulations apply;
• what personal information we collect about you;
• how we use, disclose and protect your personal information;
• with whom we may communicate your personal data;
• how you can update, manage, export and delete your information;
• how long your personal data will be kept;
• what your personal data protection rights are;
• how you can contact us to learn more about our privacy practices.

1.- DATA CONTROLLER

In terms of data protection, the Verdian Group shall be considered Data Controller regarding the personal data it collects and the data processing activities it carries out through this website or by any other means such as by telephone, email, in person, on paper through forms, through legal documents, etc., whose identification details are as follows:

• Company name: VERDIAN BV
• Dutch tax identification number 82780390
• Spanish tax identification number N0111337B
• Postal address: Hoogoorddreef 15, 1101 BA, Amsterdam (The Netherlands),
• E-mail address:  contact@verdianpower.com

2.- REGULATIONS

The Verdian Group is committed to protecting the privacy of personal data subjects by complying with current legislation (EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the Protection of Individuals with regard to the Processing of Personal Data and on the free movement of such data and repealing Directive 95/46/EC) and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights.

3.- INFORMATION WE COLLECT FROM YOU

We may collect the following information when you complete the contact form available on the Verdian website:

• Name and surname;
• E-mail address

The legal basis for this processing is the express consent you give us by accepting the privacy policy of the website.

The purpose of the processing of your personal data will be the resolution of queries and the sending of the information you request.

4.- MINORS

Minors may not make use of the services offered through the website without the prior authorisation of their parents, guardians or legal representatives, who shall be solely responsible for all acts carried out through the website by the minors in their care, including the completion of the forms with the personal data of said minors and the ticking, where applicable, of the boxes that accompany them.

6.- COMMUNICATIONS TO THIRD PARTIES

Verdian does not sell or lease your personal data to third parties and will only disclose your personal data to persons or entities if we obtain your prior consent or in compliance or pursuant to applicable law where such consent is not required for a specific transfer.

We will share or provide access to those service providers used by the Verdian Group necessary for the purposes described in this Privacy Policy, in compliance with the requirements of applicable law.

The Verdian Group may disclose your personal data to affiliated companies that are part of the Group when it is necessary for compliance with a legal obligation as well as to fulfil the purposes described in this privacy policy because the queries you make are addressed to an affiliated company. The following is a list of the subsidiaries of the Verdian Group to which your personal data may be disclosed:

7.- DURATION OF TREATMENT

We will retain your personal information for as long as necessary to fulfil the purposes for which it was collected, provided that you do not request its deletion or object to the processing of your data.

In any case, we will retain your data for as long as we are obliged to do so by law.

8.- EXERCISE OF RIGHTS

As the owner of the personal data, you may at any time exercise the following rights:

• Right to withdraw consent;
• Right of access to information that we process about you;
• The right to rectify your data if it is inaccurate or incomplete;
• The right to erasure, inter alia, when your data are no longer required for the purposes for which they were collected;
• The right to object to the processing of your data in certain circumstances, e.g. direct marketing, including drafting;
• Right to limit processing: you have the right to request the limitation of the processing of your data in the cases established by law. Likewise, the controller may limit the processing when the user contests the accuracy of the personal data, during the period that allows the controller to verify the accuracy of the data; or when the user objects to the processing, while it is being verified whether it is appropriate.
• Right to data portability: you have the right to move, copy or transfer the data you have provided to us in a structured, commonly used and machine-readable format from our database to another database. It is only possible to exercise this right in respect of the data you have provided, where the processing is based on the performance of an agreement or on your consent and the processing is carried out by automated means.
• The right to lodge a complaint with the Spanish Data Protection Agency if you consider that the processing does not comply with the regulations in force.

To do so, you must send a written request, indicating the right you are exercising, your name and surname(s), address for notification purposes, together with a copy of your ID card or other valid document proving your identity, addressed to:

• VERDIAN B.V.
• Address: Hoogoorddreef 15, 1101 BA, Amsterdam, The Netherlands,
• E-mail address:  contact@verdianpower.com

In particular, we inform you of your right to lodge a complaint with the Spanish Data Protection Agency (www.aepd.es) if you consider that the processing does not comply with the regulations in force.

9.- CHANGES TO THE PRIVACY POLICY

We are a rapidly evolving company. We will continue to evaluate this Notice in light of new technologies and services, business practices and the needs of our clients, and we will make changes to this Policy from time to time as necessary. If we make any material changes to this Notice, we will update it here.

10.- ETICO CHANNEL PRIVACY POLICY

10.1. CONTROLLER OF THE PROCESSING OF PERSONAL DATA

In terms of data protection, Verdian BV is to be considered the Data Controller regarding the personal data it collects and the data processing activities it carries out through this website or by any other means such as by telephone, email, in person, on paper through forms, through legal documents, etc., whose identification details are as follows:

• Company name: Verdian BV
•  Registered office: Hoogoorddreef 15, 1101 BA, Amsterdam, The Netherlands,
• E-mail address:  contact@verdianpower.com

Verdian is committed to maintaining strict privacy protection, data security and data retention, as detailed in our Compliance policies and procedure. These standards will also apply in respect of all personal data relating to reports made in accordance with this Policy.

The processing of personal data shall be subject to the provisions of the European Data Protection Regulation 2016/679 of 27 April 2016 and the Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights and its implementing regulations.

Verdian will keep a record of all communications received through the Ethical Channel. These records and the personal data they contain will be kept confidential. Records will be kept for no longer than is necessary and in any event for as long as is necessary to comply with any applicable legal requirements from time to time.

In particular, Verdian will keep the personal data of the complainant or complainant for the time necessary to decide whether to initiate an investigation into the facts or conduct reported or communicated and, once decided, they will be deleted from the register, and may be processed outside the system to investigate the facts for the time necessary to make a decision. Once the investigation of the communication has been completed and the appropriate actions have been taken, as the case may be, the data of those reports that have been followed up will be duly blocked in order to comply with the legal obligations that may apply in each case.

In any case, personal data from the communication of complaints shall be deleted within a maximum period of six (6) months from their introduction, unless they are retained for an additional period because they are necessary to comply with legal and corporate obligations or are necessary to provide evidence of the functioning of the crime prevention model, and may continue to be processed outside the Ethics Channel in the event that the investigation of the complaint has not been completed, for the time necessary to complete said investigation.

In the event that a complaint or claim is communicated through the ethical channel, the personal data will be kept for the time necessary to process the complaint or claim and once it has been processed, the information will be kept for statistical and quality purposes of the data controller.

10.2.- PERSONAL DATA SUBJECT TO PROCESSING

In handling reports, complaints and claims made in accordance with this Policy, Verdian collects the following personal data and information provided when making a report and throughout the investigation of the report:

• Name and contact details of the complainant (unless reporting anonymously);
• Name and details of the complainant, if necessary to process the complaint or claim.
• Name and other personal details of the persons mentioned in the complaint (alleged offender, possible witnesses and others), if such information is provided (i.e. description of functions and contact details and involvement or role with respect to the alleged facts);
• Description of the alleged infringement, as well as the circumstances of the incident(s).
• In the event of a complaint or claim, a description of the complaint or claim and the circumstances of the complaint or claim.

10.3. PURPOSE OF PROCESSING

At all times, only personal data that is strictly necessary for the purposes of managing, processing and investigating complaints relating to the commission of irregularities or acts contrary to the ethics, legality or corporate rules of Verdian and to carry out the necessary actions for the investigation of the reported facts, including, where appropriate, the adoption of the corresponding disciplinary or legal measures, will be processed.

In the case of complaints and claims, personal data are processed to the extent strictly necessary for the purpose of handling complaints and claims and, where appropriate, taking the necessary measures.

Personal data will not be used for any purpose other than that stated.

10.3. LEGAL BASIS FOR PROCESSING

The processing of personal data within the framework of the ethical channel is based on the existence of a public interest, in the terms established in article 6.1.e) of the General Data Protection Regulation, to detect and prevent complaints and the consequent prevention of damage and risks of liability of Verdian and defined in article 24 of Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights, consisting of creating and maintaining an internal complaints information system and investigating possible irregularities or acts contrary to ethics, legality or corporate rules. Likewise, the processing of data may be based on compliance with a legal obligation or the satisfaction of a legitimate interest of the company.

Therefore, the processing of the complainant’s and/or claimant’s personal data is strictly necessary to manage the complaint, claim or complaint and to comply with the aforementioned purposes and legal obligations. Under no circumstances will Verdian make automated decisions based on the data submitted.

10.4. RECIPIENTS OF PERSONAL DATA

Personal data collected in the context of a report, complaint or claim made through the Ethics Channel may be processed or communicated to the following parties where necessary:

• To the company in charge of receiving and processing complaints, claims and complaints with which an agreement for the provision of services has been entered into.
• To the Verdian Supervisory Authority.
• To Verdian’s subsidiaries that may be involved in the claim or complaint made.
• External investigators, consultants or advisors who have been engaged to support Verdian in assessing the notification, investigating the matter or advising Verdian regarding the matter;
• Police and/or other regulatory or law enforcement authorities.

The personal data collected through the complaint may be accessed by those service providers to which the Verdian Group has recourse, necessary for the reception and processing of the complaint or claim, always complying with the requirements established by the legislation in force.

10.5. DATA SUBJECTS’ DATA PROTECTION RIGHTS

As a whistleblower, the person who reports, makes a complaint or lodges a complaint may exercise, at any time and under the terms provided for by the applicable regulations, access to the personal data concerning him/her. If this person believes that the data is incorrect or incomplete, he/she may request its rectification in accordance with the applicable legislation. He or she may request that the data be erased if they are no longer required, except where there is a legal obligation to retain them. You may also request that the processing of your personal data be restricted, object to the processing of your personal data, or request the portability of your data and you have the right to withdraw your consent. You will be informed at the time you lodge your complaint, grievance or claim how you can exercise all these rights. If you consider it appropriate, you may also lodge a complaint with the competent data protection authority.