The objective of this policy is to inform interested parties about the different treatments carried out by this organization through the website and that affect their personal data in accordance with the provisions of Organic Law 3/2018, of December 5, on Protection of Personal Data and guarantee of digital rights and Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016.
Identification and contact details of the person in charge.
The organization ESA & PARTNERS, postal address: Avd Diagonal 508 4º2ª (corner of Balmes) 08006 BARCELONA, email: esa-partners@icab.es.
Purposes of the processing of your personal data.
Users/navigators of the website of the person in charge: We will process your personal data provided through our web forms to:
• Respond to requests, complaints and incidents reported through our contact channels incorporated into the website.
• Understand the behavior of the navigator within the web in order to detect possible computer attacks on our website.
• Comply with the legal obligations that are directly applicable to us and regulate our activity.
• To protect and exercise our rights or respond to claims of any kind.
• If applicable, sending commercial communications related to the goods or services that make up our activity, and/or news or bulletins related to our sector.
• Manage and send you the requested budget
• We manage your data to schedule the requested appointment
• Manage, administer, monitor your activity on the built-in blog/forum.
Customers: We will treat your personal data provided through our web forms to:
• The management of the business relationship.
• The provision of the services that you have contracted with us.
• Administrative, accounting and fiscal management.
• Respond to requests, complaints and incidents reported through our contact channels incorporated into the website.
• Understand the behavior of the navigator within the web in order to detect possible computer attacks on our website.
• If applicable, carry out quality surveys that allow us to evaluate our service.
• If applicable, carry out raffles.
• If applicable, sending commercial communications related to the goods or services that make up our activity, and/or news or newsletters related to our sector.
• Comply with the legal obligations that are directly applicable to us and regulate our activity.
• To protect and exercise our rights or respond to claims of any kind.

Legal basis of the treatment.
Users/browsers on the website of the person in charge.
• In the consent you have given us to process your data for the indicated purposes. The refusal to provide your personal data will entail the impossibility of processing your data for the aforementioned purposes.
• To comply with legal obligations that apply to us. In this case, the interested party may not refuse the processing of personal data.
• In our legitimate interest to protect our image, business and trajectory by avoiding attacks on our website. In this case, the interested party may not refuse the processing of personal data, although they may exercise, where appropriate, the rights recognized in section eight of this policy.
Customers.
• Execution of a contract in which it is a party or application of pre-contractual measures. The refusal to provide your personal data will entail the impossibility of processing your data for the aforementioned purposes.
• In the consent you have given us to process your data for purposes other than the development or execution of the existing contract. The refusal to provide your personal data will entail the impossibility of processing your data for the aforementioned purposes.
• To comply with legal obligations that apply to us. In this case, the interested party may not refuse the processing of personal data.
• In our legitimate interest to protect our image, business and trajectory by avoiding attacks on our website. In this case, the interested party may not refuse the processing of personal data, although they may exercise, where appropriate, the rights recognized in section eight of this policy.
Deadlines or criteria for data conservation.
The personal data provided will be kept for the time necessary to fulfill the purposes for which they were initially collected. Once the data is no longer necessary for the treatment in question, it will be kept duly blocked in order, where appropriate, to make it available to the competent Public Administrations and Bodies, Judges and Courts or the Public Prosecutor’s Office, during the limitation period. of the actions that could derive from the relationship maintained with the client and/or the legally established retention periods.
• THE CIVIL CODE. Between 5 or 15 years depending on the case, in accordance with the provisions of article 1964.2 of the aforementioned legal body.
• THE CODE OF COMMERCE. For 6 years, in accordance with the provisions of article 30 of the aforementioned legal body. It applies to commercial information related to (invoices issued and received, tickets, corrective invoices, bank documents, etc.).
• THE GENERAL TAX LAW. For 4 years in accordance with the provisions of articles 66 to 70 of the aforementioned legal body. It applies to information related to tax obligations.

• LAW 10/2010, OF APRIL 28, ON THE PREVENTION OF MONEY LAUNDERING AND THE FINANCING OF TERRORISM. For 10 years in accordance with the provisions of 25 of the law.
Automated decisions and profiling.
The website does not make automated decisions or create profiles.
Recipients
During the duration of the processing of your personal data, the organization may transfer your data to the following recipients:
• Judges and Courts.
• State Security Forces and Bodies.
• Other authorities or competent public bodies, when the person in charge has a legal obligation to provide personal data.
• Banks and Financial Entities, in the event that you hire us.
International data transfers.
The organization does not carry out any international data transfer.
Rights.
Interested parties may exercise at any time and completely free of charge the rights of access, rectification and deletion, as well as request that the processing of their personal data be limited, oppose it, request the portability of these (provided that it is technically possible). or withdraw the consent given, and where appropriate, where appropriate, not to be the subject of a decision based solely on automated processing, including profiling.
For this, you can use the forms provided by the organization, or send a letter to the postal address or email indicated above. In any case, your request must be accompanied by a photocopy of your D.N.I. or equivalent document, in order to prove your identity.
In the event that you feel your rights have been violated with regard to the protection of your personal data, especially when you have not obtained satisfaction in the exercise of your rights, you can file a claim with the competent Data Protection Control Authority (Agency to Spanish Data Protection), through its website: www.agpd.es.
In compliance with the provisions of article 21 of Law 34/2002 on services of the information society and electronic commerce, if you do not wish to receive more information about our services, you can unsubscribe by sending an email to the address that -partners@icab.es, with the subject “LOWS”.
Veracity of the data.
The interested party guarantees that the data provided is true, exact, complete and updated; committing to inform of any change regarding the data provided, through the channels enabled for this purpose and indicated in point one of this policy. It will be responsible for any damage or loss, both direct and indirect, that could be caused as a result of the breach of this obligation.
In the event that the user provides data from third parties, he declares that he has the consent of the interested parties and undertakes to transfer the information contained in this clause, exempting the organization from any responsibility derived from the lack of compliance with this obligation. .