Policy responsible for the treatment:

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“Behave4 Management Consulting, S.L.” (hereinafter, also “Behave4”), owner of this Website, informs visitors to the Website, and registered Users about its policy of protection of personal data (hereinafter, “Personal Data”) so that Users can freely and voluntarily determine if they wish to provide BEHAVE4 with the Personal Data that may be required or that may be obtained on the occasion of contracting, subscription or registration in any of our newsletters , request for information about any of our business consulting services in HR, request to register a User, or as a participant in activities / promotions or surveys organized by BEHAVE4. BEHAVE4 reserves the right to modify this policy to adapt it to new legislation or jurisprudence as well as industry practices. In such cases, BEHAVE4 will announce on this page the changes introduced with reasonable anticipation of their implementation. Certain services provided/offered through our website may contain particular conditions with specific provisions on the protection of Personal Data.

The data collected by any of the contact forms enabled on this Website, use and registration, or by any other means or contact, will be incorporated, depending on their purpose and the reason for their consultation / contact, to automated files owned by BEHAVE4. The files indicated are registered in the General Registry of the Spanish Agency for Data Protection (see registry).

BEHAVE4 reserves the right to modify this policy to adapt it to new legislation or jurisprudence as well as industry practices. In such cases, BEHAVE4 will announce on this page the changes introduced with reasonable anticipation of their implementation. Certain services provided on the Portal may contain particular conditions with specific provisions on the protection of Personal Data.

BEHAVE4, as Responsible for the processing of the User’s personal data, informs you that these data will be treated in accordance with the provisions of Regulation (EU) 2016/679 of April 27, 2016 (GDPR) on the protection of natural persons with regard to the processing of personal data and the recent Organic Law 3/2018 of December 5 (L.O.P.D.-G.D.D.) on the protection of personal data and Guarantee of Digital Rights.

Information / Data processed:

Merely identifying data (name + surname) and contact data where appropriate (address, telephone and email address).

responsible for the treatments:

“Behave 4 Management Consulting, S.L.” (hereinafter, “Behabe4”)
Tax ID: B-19.650.092
Registered Office: C/ Periodista Fernando Gómez de la Cruz, nº 65, CETIC 1st floor Building, CP: 18014 – Granada
Contact email: legal@kodopeople.com

Intended processing purposes: maintenance of the existing contractual relationship and the commercial relationship with users and interested parties in BEHAVE4. In this sense, the operations planned to carry out the treatment are:

Sending commercial advertising communications by email, SMS, Wasap, social networks or any other electronic or physical means, present or future, that makes it possible to make commercial communications. These communications will be made by the RESPONSIBLE and related to the strategic and business consulting services in HR of BEHAVE4, or its collaborators or suppliers with whom it has reached a promotion agreement. In this case, third parties will never have access to personal data.
Actions requested by the User: Process requests or any type of request that, on the services of BEHAVE4, is made by the user through any of the contact forms that are made available through our Website:
https://kodopeople.com/contact
https://kodopeople.com/

In the aforementioned forms, you are allowed to provide, among others, the following personal data:

Your name and surname and contact details (address, telephone numbers and email).
Other contact details and preferences.
We collect your data if you contact us through the Site.
When you attend any of our events/presentations and conferences, we will collect your data, if you fill out any of our promotion or subscription forms. In any case, these options are voluntary and will be previously informed with the corresponding informative legal legends.
If the personal data have been provided by the users, they must be truthful, and BEHAVE4 must be notified of any modification that occurs in them, responding in any case to the veracity and accuracy of the data provided at all times.
The interested party who provides their personal data to BEHAVE4, declares to be of legal age being entirely responsible for said declaration.
DATA STORED DURING YOUR VISIT: When you visit our website, our web servers generally store, among other data, information about the browser and operating system you use, the website from which you visit us, the pages you visit on our website and the date of your visit. For security reasons – for example, in order to detect possible attacks on our website – the IP address assigned to you by your Internet service provider is also stored for a period of seven days. With the exception of the IP address, personal data is only stored if you provide us with such information, for example, on the occasion of a registration, a survey, a request for a quote, user registration, commercial promotion. BEHAVE4 uses your personal data for the technical administration of the web pages, the management of clients, the realization of HR surveys and for marketing tasks, only to the extent necessary, and always informing the User and owner of the data in advance.
NEWSLETTER /NEWSLETTERS SUBSCRIPTION: In the case of subscription to any of our newsletters , present or future, as reported, you consent to the use of your personal data for the sending of advertising or the performance of other marketing actions, these will be stored and used continuously for such uses, such as sending newsletters already mentioned, news in our strategic and business consulting services in HR, through communication channels such as e-mail, postal mail or any other channel authorized by you. We may use your data to create and keep your user profile up to date so that we can send you personalized information about advertising actions or promotions. Likewise, we may use the data you provide us to analyze and improve the effectiveness of our website services, advertising, marketing, market prospecting and sales activities.
SENDING OF C. VITAE BY CANDIDATES: In case of sending C. Vitae to the email of BEHAVE4 legal@kodopeople.com, or through the form enabled for this purpose: https://kodopeople.com/#_contact, the applicant authorizes BEHAVE4 to analyze the documents that it sends him, all the content that is directly accessible through the search engines (Google), the profiles that he maintains in professional social networks, such as Linkedin or similar, the data obtained in the entrance exams and the information you reveal in the job interview, with the aim of assessing your candidacy and being able, where appropriate, to offer you a position. In the event that the candidate is not selected, BEHAVE4 may keep his C. VITAE stored to incorporate it into future calls, unless the candidate manifests himself in the opposite direction, through: https://kodopeople.com/contact

Data conservation criteria:

The data provided, in general, will be kept as long as there is a mutual interest to maintain the purpose of the treatment and when it is no longer necessary for that purpose, they will be deleted with adequate security measures to guarantee the pseudonymization of the data or the total destruction of the same.

Given this general rule, the following possible variations are proposed: (i) Disaggregated Data: they will be kept without a deletion period, (ii) BEHAVE4 Customer Data: conservation period of 4 years (Art. 66 and following of the General Tax Law), conservation period of 6 years Art. 30 of the Commercial Code on accounting books and invoices), (iii) Data provided on the occasion of the subscription to our newsletter: from the moment the User gives his consent, until he withdraws it, (iv) Documentation of a labor nature or related to social security: 4 years Article 21 of Royal Legislative Decree 5/2000, of August 4, which approves the revised text of the Law on Infractions and Sanctions in the Social Order (v) data provided by candidates through the sending of your C. Vitae: the C. Vitae may be kept for a maximum of two years for future selection processes unless the candidate states otherwise.

Communication of the data: The data will not be communicated to any recipient.

As a general rule, prior to the processing of personal data, BEHAVE4 obtains express and unequivocal consent from the owner of the same by incorporating informed consent clauses in the different information collection systems, and based on a legitimate interest of the User.

Legitimation FOR INFORMED TREATMENTS: the bases of legitimation are the following:

When the processing is necessary for the execution of a contract to which it is a party or the data are necessary within the framework of a pre-contractual relationship.
When the use of your personal data is necessary for the satisfaction of our legitimate interests or those of the companies with which we have shared your personal data for the needs of the contracted service and provided that the communication has been authorized.
When the processing of the data is necessary to comply with the legislation / regulations governing the legal obligations of the sector, in force at all times, among which are the one related to the placing on the market of products and services, defense of consumers and users, and other applicable regulations.
In accordance with the provisions of the applicable regulations of Services of the Information Society (LSSI), if there is a previous commercial relationship, the data may be used to send electronic commercial communications referring to our activity / services, unless you oppose it in the manner provided for this purpose.
Where we consider that it is necessary to process your personal data in order to comply with a legal or regulatory obligation, or a vital interest.
Where we have your consent, for example, to collect technical information such as cookie data and similar technologies as described in: “Cookie Usage Information”.
The acceptance of a contractual relationship in the environment of the corresponding social network, and in accordance with its Privacy policies in each case:
- Linkedin (https://www.linkedin.com/legal/privacy-policy)
- Twitter (https://twitter.com/es/privacy).

However, in the event that the consent of the interested party is not required, the legitimizing basis of the treatment in which BEHAVE4 is protected is the existence of a CONTRACT FOR STRATEGIC CONSULTING SERVICES OF EQUIPMENT AND HR BEHAVE4.

Rights that assist the User:

Right to withdraw the consent provided at any time.
Right of access and rectification of your data.
Right to erasure (right to be forgotten) of your data.
Right to limitation or opposition to its treatment.
Right to the portability of your data: understood as the right to receive your data in a structured, commonly used and machine-readable format, and to transmit them to another data controller (Art. 20 GDPR)
Right to file a complaint with the supervisory authority (agpd.es) if it considers that the treatment does not comply with current regulations.

Contact data to exercise your rights: BEHAVE4, in application of Regulation (EU) 2016/679 of April 27, 2016 (GDPR), and Organic Law 3/2018 of December 5 (L.O.P.D.-G.D.D.) on the protection of personal data and Guarantee of Digital Rights.

We provide the data:

Address: Avda. del Conocimiento nº41, Centro de empresas PTS, Oficina A204. 18016, Granada, Spain
Contact email address: legal@kodopeople.com

Mandatory or optional nature of the information provided:

The data collected by any of the contact forms enabled on this Website, or even for the provision of strategic and business consulting services in HR “BEHAVE4”, or those provided by Users on the occasion of their participation in activities / events developed by BEHAVE4, will be incorporated, depending on their purpose, to files registered with the Spanish Agency for Data Protection and the Register of Internal Treatment Activities (Article 30 of Regulation (EU) 2016/679 of 27 April 2016). The Register of Processing Activities is available to the Supervisory Authority.

Users, by marking the corresponding boxes and entering data in the different fields, marked with an asterisk (*) in the contact form or presented in download/ contracting forms, expressly and freely and unequivocally accept that their data is necessary to meet their request, by BEHAVE4, being voluntary the inclusion of data in the remaining fields. The User guarantees that the personal data provided are true and is responsible for communicating any modification thereof.

BEHAVE4 expressly informs and guarantees users that their personal data will not be transferred in any case to third parties and that, whenever it plans to make any transfer in the future, the express, informed and unequivocal consent of the Users will be previously requested, informing about the data of the assignee, and the purpose of the assignment. All data requested through the website are mandatory, as they are necessary for the provision of an optimal service to the User. In the event that all the data is not provided, it is not guaranteed that the information and services provided will be completely adjusted to your needs.

Security measures:

In accordance with the provisions of current regulations on the protection of personal data, and in particular Regulation (EU) 2016/679 of April 27, 2016, BEHAVE4 is complying with all the provisions of the regulations RGPD 679/2016 and LOPD-GDD 3/2018 for the processing of personal data under its responsibility, and manifestly with the principles described in article 5 of the GDPR, by which they are treated in a lawful, loyal and transparent manner in relation to the interested party and adequate, relevant and limited to what is necessary in relation to the purposes for which they are treated.

In any case, BEHAVE4 has implemented sufficient mechanisms to:

Guarantee the permanent confidentiality, integrity, availability and resilience of the processing systems and services.
Restore availability and access to personal data quickly, in the event of a physical or technical incident.
Verify, evaluate and assess, on a regular basis, the effectiveness of the technical and organizational measures implemented to guarantee the security of the treatment.
Pseudonymize and encrypt personal data, if any.

BEHAVE4 guarantees that it has implemented appropriate technical and organizational policies to apply the security measures established by the GDPR and the LOPD-GDD in order to protect the rights and freedoms of Users and has communicated the appropriate information so that they can exercise them. BEHAVE4 has installed all the means and technical measures at its disposal to prevent the loss, misuse, alteration, unauthorized access and theft of the Personal Data provided by the owner to BEHAVE4. However , the User must be aware that internet security measures are not impregnable.

The personal data that are incorporated into the Register of Internal Treatment Activities, will be treated with the utmost confidentiality and security, the Owner of the indicated File may send you commercial information related to NEWS ABOUT THE SERVICES CONTRACTED AND OFFERED BY BEHAVE4, in this case, the sender undertakes to indicate its advertising purpose when sending, and to coordinate a simple, clear and free system for the case in which you wish to stop receiving them.

The BEHAVE4 Services contained on the website are intended exclusively for adults, in the event that BEHAVE4 offers any promotional activity, event, conference or similar, in which the collection of Personal Data of minors may occur, BEHAVE4 will always request parental consent so that minors can access them and their Personal Data can be subject to automated processing as provided in this notice. on the Data Protection Policy.

As previously reported, the collection and automated processing of Personal Data is intended to maintain the contractual relationship, if any, established with BEHAVE4, the management, administration, provision, extension and improvement of the services that the User decides to contract, register, or use the adequacy of said services to the preferences and tastes of the Users, the study of the use of the services by the Users, the design of new sports services related to said services, the sending of updates of the services, the sending, by traditional and electronic means, of technical, operational and commercial information about HR consulting projects and related services offered by BEHAVE4 currently and in the future.

Social Networks:

BEHAVE4 has a profile on the main social networks of the Internet (Linkedin and Twitter) knowing in all cases responsible for the processing of the data of its followers, fans, subscribers, commentators and other user profiles (hereinafter, followers). The treatment that BEHAVE4 will carry out with said data will be, at most, the one that the social network allows to the corporate profiles. Thus, BEHAVE4 will be able to inform its followers by any means that the social network allows about its news, activities, promotions. In no case will BEHAVE4 extract data from social networks, unless the user’s consent for it was obtained punctually and expressly. When, due to the very nature of social networks, the effective exercise of the rights of the follower is subject to the modification of the personal profile of the latter, BEHAVE4 will help and advise him to that end to the extent of his possibilities.

Linkedin: https://www.linkedin.com/company/kodopeople/
Twitter: https://twitter.com/kodopeople
Instagram: https://www.instagram.com/kodopeople/
Facebook: https://www.facebook.com/KodoPeople

For what purposes are we going to treat your personal data?

Respond to your queries, requests or requests.
Manage the requested service, answer your request, or process your request.
Relate to you and in a community of followers.

What is the legitimacy for the processing of your data?

The acceptance of a contractual relationship in the environment of the corresponding social network, and in accordance with its Privacy policies:

Linkedin (https://www.linkedin.com/legal/privacy-policy)
- Twitter (https://twitter.com/es/privacy).

KNOWING BEHAVE4 in all cases responsible for the processing of the data of its followers, fans, subscribers, commentators and other user profiles (hereinafter, followers). The treatment that BEHAVE4 will carry out with said data will be, at most, the one that the social network allows to the corporate profiles. Thus, BEHAVE4 will be able to inform its followers by any means that the social network allows about its news, activities, promotions. In no case will BEHAVE4 extract data from social networks, unless the user’s consent for it was obtained punctually and expressly. When, due to the very nature of social networks, the effective exercise of the rights of the follower is subject to the modification of the personal profile of the latter, BEHAVE4 will help and advise him to that end to the extent of his possibilities.

CONTACT: Please, if you have any questions about this Privacy Policy, please contact us through:

BEHAVE4: Avda. del Conocimiento nº41, Centro de empresas PTS, Oficina A204. 18016, Granada, Spain

Email: legal@kodopeople.com

Contact Form: https://kodopeople.com/contact/

Drafting of Privacy Policy updated and revised as of March 1, 2022.