With this Privacy Policy, the Enagás Group wishes to inform you about how we collect and process personal data you provide to us. Accordingly, we comply with the principle of transparency provided in the new data protection regulation.
We hereby inform you that your data will be processed in accordance with Spanish Organic Law 3/2018 on the Protection of Personal Data and the guarantee of digital rights and with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the “GDPR”).
This Policy applies to all data processing operations carried out by companies in the Enagás Group. However, it does not apply to third-party websites, including external websites accessed via links on our websites.
The main entity responsible for processing your data is Enagás S.A. (hereinafter “Enagás”); however, data may also be processed by companies in the Enagás Group, depending on the relationship you have with each company. When your data is collected, you will be informed of the identification details of the data controller in each case. The locations and functions of the companies in the Enagás Group are available at www.enagas.es.
In addition, we would like to inform you that if you have any queries in connection with the processing of your data, you can email us on protecciondedatos@enagas.es or write to our head office in Paseo de los Olmos 19, 28005 Madrid, Spain.
By way of example, we may process the following personal data by the following means:
When special conditions apply to the processing, you will be informed specifically of the processing operation and purpose, and these conditions shall prevail over this Privacy Policy.
By way of example, we inform you that Enagás may process your personal data for the following purposes:
a) To attend to a customer, user or data subject
You will find our contact details on the website, including our address, telephone number and email address. We use these channels to process your data to respond to queries, suggestions and complaints you send us. The legal basis for the processing is the performance of the contractual or pre-contractual relationship (application for service).
b) To carry out surveys and events
After you have visited our premises, we may process your business contact details for the purpose of managing your relationship with Enagás and to inform you about corporate events that may be of interest to you and to conduct surveys about our services.
The processing operation is based on Enagás’ legitimate interest in managing and maintaining the business relationship with you, and to tell you about services you have shown an interest in.
In addition, if you attend an event in a personal capacity, we may process your data so that we can invite you to other events organised by the Enagás Group and, in such cases, we may take photos at the event which will be published on our website. In any event, we will notify you in advance so that you can make a decision accordingly. In this case, we rely on your consent as the legal basis for the processing.
c) For entrepreneurship projects and initiatives
AWe may receive projects you send us under the Enagás Corporate Entrepreneurship and Innovation programme via our website www.emprende.enagas.es.
The legal basis for the processing in this case is Enagás’ interest in providing you with information in relation to your application and participation in the programme and to evaluate your project
d) To manage data relating to contract representatives and potential customers
To manage and perform the contractual relationship we have with companies such as shippers, distributors and/or suppliers, we process the contact details of the companies’ representatives. Therefore, the legal basis for the processing is the performance of the contract between the two parties.
Similarly, we process the data of potential customers, such as legal persons, representatives of institutions and public bodies, journalists, analysts, investors and shareholders, who have provided us with their personal data. The legal basis for the processing in this case is the consent given by the data subject.
e) For relations with suppliers
Enagás may process the data of supplier’s employees (provided either by the supplier or the employee) to ensure the quality of the service provided by the supplier, allow access to Enagás’ facilities and to comply with legal obligations in relation to social security. The legal basis for the processing is our legitimate interest in overseeing the relationship with our suppliers and the associated responsibilities.
f) To send Enagás news and publications
We will process your personal details to send you news about the Enagás Group and its activities when you subscribe to our newsletter. We will only process the data if we have your consent, and this consent is the legal basis for the processing.
g) For job offers
We regularly publish job offers and also have a channel for the receipt of speculative applications. If you contact us because you are interested in joining the Enagás team, we will process your data and any documents you send for the purposes of assessing your application and considering you for job vacancies that arise in Enagás. Therefore, it is possible that we will share your data with the company in the Enagás Group looking to fill a vacancy. The legal basis for the processing in this case is the consent you give when completing and submitting the job application form.
h) For training
We organise training activities both for our employees and third parties. If you take part in a training activity organised by Enagás, we will process your data for the purpose of managing your participation and gauging your satisfaction with the training.
The legal basis for the processing is our legitimate interest in promoting the exchange of knowledge and skills of our employees and, if you are not an employee, the consent you gave when registering for the training course.
i) To control access to our premises
When you access our facilities, we process your data in order to keep track of visitors to our premises. In this case, the legal basis for the processing is Enagás’ legitimate interest in ensuring the safety of Enagás Group premises.
j) For video surveillance
We operate video surveillance cameras for the purpose of ensuring the safety of the employees and property of the Enagás Group. The legal basis for the processing is our legitimate interest in preventing or investigating, where applicable, any incidents against people or property that occur on Enagás premises.
k) To comply with our responsibilities
We will process your data when this is required for compliance with our tax, employment and/or administrative obligations. The legal basis for the processing is compliance with our legal obligations in each case.
We will keep your personal data for the time required to fulfil the purpose of collection, such as to respond to a query or complaint, or as long as you have a contractual relationship with us, provided you do not exercise your right of erasure, we are required to retain your data in compliance with a legal obligation or for the exercise or defence of legal claims. We will inform you of the criteria and duration of the processing in each specific case.
After the contractual relationship has ended, we will retain your data after blocking them to make them available to the public authorities or courts for possible criminal, civil, commercial and/or administrative liabilities arising out of the processing and to exercise and defend ourselves against complaints from the Spanish Data Protection Agency.
If Enagás intends to disclose your personal data, when your data is collected, you will be informed of the recipients or categories of recipients to whom the data are disclosed, such as:
In addition, we have relationships with third-party suppliers who, in their capacity as data processors, provide us with certain services. Enagás, for its part, requires that data processors provide sufficient guarantees in relation to the protection of your data.
In the event that your data is accessed by companies in countries outside the European Economic Area (EEA) that do not offer an adequate level of protection similar to that afforded by the EEA, we will require that they comply with one of the guarantee mechanisms provided in the GDPR.
To safeguard your personal data, Enagás has taken all technical and organisational measures to ensure the security, integrity and confidentiality of your personal data and to avoid their alteration, loss and/or unauthorised access or processing.
In order to keep your personal data up-to-date in our Record of Processing Activities, you are required to inform us of any changes to your personal information, otherwise we cannot accept responsibility for data that is not accurate or truthful, or for the consequences this may have for the Enagás Group or third parties.
Enagás has a presence on social media. Therefore, if you decide to include personal information in these media, your data will be processed in accordance with this Privacy Policy. Specifically, the data you provide through our social media pages will be processed by Enagás S.A., with registered office at C/ Paseo de los Olmos No. 19, Madrid, for the purpose of interacting and communicating with you via social media to better acquaint you with our activities and expertise.
The legal basis for the processing is your status as a “user”, “friend” or “follower” of our social media profile or to be able to respond if you mention our profile in your comments, even if you are not a follower; in the latter case, we will process the minimum data needed to reply to you.
Once you stop “following” our social media profile, we will retain your data for a period of two years.
Nevertheless, when interacting with us on social media, you should be aware that the terms of use are determined by each social media platform and are therefore beyond our control and not covered by this Privacy Policy. Therefore, we recommend that you know and agree with their legal terms and privacy policies before you use them or provide personal information.
In any event, we recommend that you avoid including your own or other people’s personal data when communicating with us on social media.
In general, Enagás does not process the personal data of persons under 18 years. Both the content and services we offer are generally intended for people over the age of 18.
However, we may occasionally hold corporate events that are attended by minors. In such cases, we will not process their data (name, surname, photograph, image, etc.) without first notifying the minor’s parent or guardian about the processing and obtaining their consent if the minor is under the age of 14 years.
Enagás accepts no responsibility for personal data published by minors on our social media pages without their parents or guardian’s consent.
You may exercise your rights of access, rectification, erasure, restriction, portability and objection to the processing of your data and automated decision-making at any time by sending a written request to protecciondedatos@enagas.es or to the address: Paseo de los Olmos 19, 28005 Madrid, including a photocopy of your national ID card or equivalent identity document and specifying the rights you wish to exercise.
If a legal or voluntary representative is acting on your behalf, they must also provide a document to this effect and their identity document.
In addition, if you gave your consent to a specific processing operation at some point but wish to withdraw it, you may do so by sending a written request to protecciondedatos@enagas.es or the address indicated above.
Templates, forms and additional information about the above rights can be found on the Official website of the Spanish Data Protection Agency.
If you believe your rights under the regulations have been infringed, you may send a complaint to proteccióndedatos@enagas.es or the data protection authority which, in Spain, is the Spanish Data Protection Agency (www.aepd.es).
We accept no responsibility for the truthfulness, accuracy, validity and/or authenticity of the data you provide us or the consent given. Furthermore, Enagás is not responsible for data you provide relating to third parties when you have not obtained their consent.
This Policy may be amended at any time, and you will be notified of any important changes. Your data will be processed in accordance with the provisions of the new Policy; therefore we recommend that you check the Policy from time to time.
