Identity of the data controller
Entity responsible for the processing of personal data | Controller | Hard2bit S.L. |
| Tax ID | B86717147 |
| Address |
Avenida Juan Caramuel No. 1, Parque Tecnológico de Leganés, 28919, Madrid, Spain
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| Telephone | 910139827 |
| Website | https://hard2bit.com/ |
| Internal Privacy Contact | thilina.manana@hard2bit.com |
Processing of personal data
The main areas in which Hard2bit S.L. processes personal data are described below,
including the purpose of processing, legal basis, categories of data, source,
recipients, and retention periods.
Human resources
| Purpose of processing | - Formalization and maintenance of the employment relationship.
- Management of payroll, contracts, and administrative obligations.
- Work organization and task planning.
- Compliance with tax, labor, and Social Security obligations.
- Working time recording and compliance with labor regulations.
- Making information available to the Labor Inspectorate where required.
- Management of job applications and recruitment processes.
- Assessment of professional profiles.
- Management of internship agreements and training contracts.
- Organization and management of training activities.
- Processing of training subsidies where applicable.
- Compliance with occupational health and safety obligations.
- Management of medical examinations and workplace accidents.
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| Legal basis | - Performance of the employment contractual relationship.
- Compliance with legal obligations in labor, tax, and Social Security matters.
- Compliance with occupational risk prevention obligations.
- Legitimate interest in internal organization and management.
- Where applicable, the data subject’s consent when required.
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Where health data are processed, such processing is carried out under the
applicable labor and social security regulations.
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| Types of data processed | - Identification data (name, ID number, address, telephone, email).
- Professional and academic data.
- Financial and banking data.
- Working time data.
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Health data strictly necessary in the employment context (medical leave,
workplace accidents, fitness for work, excluding diagnoses).
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| Source of the data | - Directly from the data subject.
- From legal representatives or authorized persons.
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Where applicable, from sources derived from the contractual or administrative
relationship, or from files related to the request or claim.
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| Recipients | - Tax Administration.
- Social Security authorities.
- Labor Inspectorate.
- Financial institutions.
- Mutual insurance entities and insurers.
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External entities providing services as processors, such as labor advisory
firms or software providers.
As a general rule, no international transfers of personal data outside the
European Economic Area are carried out. Should this occur, compliance with the
safeguards required under the GDPR will be ensured.
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| Retention period |
Data will be retained for as long as necessary to fulfill the purposes
described above and, subsequently, for the legally required periods under
labor, tax, and Social Security regulations.
Recruitment data will be retained for a maximum period of one year, unless
updated earlier by the data subject.
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Administrative, financial, and operational activities
| Purpose of processing | - Supplier and procurement management: orders, contracting,
service provision, invoicing, payments, communications, and related
administrative management.
- Customer management and service delivery: provision of
services or products, invoicing, collections, communications, and related support.
- Administrative, accounting, and tax management: payments,
collections, bookkeeping, tax obligations, and management of subsidies or
economic relations where applicable.
- Handling requests, complaints, suggestions, and claims:
management and response through in-person or electronic channels.
- Exercise of data protection rights: processing and response
to requests under the GDPR, including access, rectification, erasure,
objection, restriction, and portability where applicable.
- Claims and proceedings: management of liability claims,
administrative and judicial proceedings, and legal defense where applicable.
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| Legal basis | - Performance of a contract or pre-contractual relationship.
- Compliance with legal obligations.
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Legitimate interest in the ordinary management of relationships with contact
persons at suppliers or clients, and in handling and responding to requests or claims.
- Consent where necessary.
- Defense of claims and proceedings.
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| Types of data processed | -
Identification and contact data (name, surname, ID / Tax ID, address,
telephone, email, signature).
- Professional data (position, company, professional contact details).
- Financial and banking data (banking details, invoicing, transactions).
- Data necessary for the management of requests, complaints, or claims.
- Where applicable, information associated with a file or claim.
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| Source of the data | - Directly from the data subject.
- From legal representatives or authorized persons.
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Where applicable, from sources derived from the contractual or administrative
relationship, or from files related to the request or claim.
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| Recipients | -
Competent public authorities, including the Tax Administration, consumer
authorities, or other bodies with jurisdiction.
- Financial institutions.
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The Ombudsman and the Spanish Data Protection Agency (AEPD), where applicable.
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Courts, Tribunals, Law Enforcement authorities, and relevant professionals in
the context of proceedings or claims.
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Service providers acting as processors under a GDPR-compliant data processing agreement.
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| Retention period |
We will retain the data for as long as necessary to fulfill the purpose for
which they were collected and, subsequently, for the periods required by
applicable accounting, tax, administrative, and limitation regulations.
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Monitoring and control
| Purpose of processing | Access to our premises and ensuring the security of those premises. |
| Legal basis | -
Performance of the contractual relationship, in the case of employees or
authorized staff.
- Legitimate interest in protecting premises and controlling access.
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| Types of data processed | - Name and surname.
- Identification document, where applicable.
- Access logs (date and time).
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| Source of the data |
Data are obtained directly from the data subject at the time of entry, or
through identification or registration when necessary for access control.
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| Recipients | - Law Enforcement authorities.
- Courts and Tribunals.
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| Retention period |
Access control data will be retained for a maximum period of one month, unless
they must be retained for security reasons or for the investigation of incidents.
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Information and communication technologies
| Purpose of processing | - IT support and incident management: management and
resolution of incidents, root cause analysis, ticket tracking, documentation
of corrective actions, and improvement of the security and quality of systems.
- Website management: handling web form inquiries, user
registrations, navigation administration, user experience improvements, and site security.
- Social media management: administration of corporate
profiles, publication of content, interaction with users, and dissemination
of institutional or commercial information.
- Communications (WhatsApp or other channels): handling
inquiries and requests, and providing information related to contracted or requested services.
- Security incident and breach management: detection,
analysis, and documentation of incidents, risk assessment, and compliance
with notification obligations to authorities.
- Equality and diversity: prevention, detection, and
investigation of harassment situations; ensuring equality, non-discrimination,
and regulatory compliance.
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| Legal basis | - Performance of a contract or pre-contractual relationship.
- Compliance with legal obligations.
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Legitimate interest in ensuring security, the operation of systems, and internal organization.
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Consent where necessary, for example for the use of image or commercial communications.
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| Types of data processed | - Identification data (name, email address, telephone number).
- IP address and browsing data.
- Data included in tickets or support requests.
- Image and/or voice, where express authorization has been given.
- Information related to security incidents.
- Data necessary for internal equality management protocols.
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| Source of the data | - Directly from the data subject.
- Through web forms.
- Through electronic communications.
- Derived from incident analysis or the use of systems.
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| Recipients | - Relevant internal departments.
- Technology providers acting as processors.
- Social media platforms.
- WhatsApp as a messaging service provider.
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Competent authorities, the AEPD, and Law Enforcement authorities where there
is a legal obligation.
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| Retention period | - For as long as necessary for the purpose for which the data were collected.
- For the limitation periods applicable to potential liabilities.
- In the case of technical incidents, up to a maximum of 5 years in blocked form.
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On social media, while the content remains published, until its removal is
requested, or according to the agreement signed between the parties.
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International transfers
As a general rule, no international transfers of personal data outside the European
Economic Area are carried out. Should this be necessary, the safeguards required under the GDPR will be adopted.
What are your rights and how can you exercise them?
You may exercise at any time the rights recognized under personal data protection
regulations, in particular:
- Access: to know what personal data we process about you.
- Rectification: to request correction of inaccurate or incomplete data.
- Erasure: to request deletion of your data where applicable.
- Objection: to request that your data not be processed in certain circumstances.
- Restriction of processing: to request limitation of processing in cases provided by law.
- Portability: to request delivery of your data in a structured format where applicable.
- Withdraw consent: where processing is based on consent, you may withdraw
it at any time, without affecting the lawfulness of prior processing.
To exercise these rights, you may use the form available on our website in the privacy
section, where you can specify the type of request and provide the information
necessary for its processing. Additionally, you may submit your request through the
contact channels indicated in this Policy.
If you become aware of or suspect any misuse of your personal data in the context of
our services or in relation to our authorized providers, please inform us as soon as
possible through the channels indicated in this Policy so that we may analyze the
situation and adopt the corresponding measures.
Likewise, in order to ensure that the information we process is accurate and up to
date, we would appreciate it if you inform us of any changes in your data or if you
detect that any data are incorrect, so that we can review and update them.
Right to lodge a complaint with the supervisory authority
If you consider that the processing of your personal data does not comply with the
applicable regulations, you have the right to lodge a complaint with the Spanish Data
Protection Agency (AEPD).
Automated decisions
No automated decisions, including profiling, are taken that produce legal effects
concerning you or similarly significantly affect you, unless expressly stated otherwise
in the specific context of the processing.
Security measures
The organization applies appropriate technical and organizational measures to ensure a
level of security appropriate to the risk, in order to protect personal data against
unauthorized access, loss, alteration, disclosure, or destruction.
| Description |
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The organization manages information security under an Information Security
Management System (ISMS) and practices aligned with the international ISO/IEC
27001 standard and the Spanish National Security Framework (ENS) at high category.
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